Sludge Watch ==> Flies, Odor, Fecal Dust, ..read Power Company testimony re Nursery Products

maureen.reilly at sympatico.ca maureen.reilly at sympatico.ca
Sat May 20 16:07:39 EDT 2006


Sludgewatch Admin-
Please please read the whole report from the PDF file... the section
starts on electronic page 37....or just start reading below...I know
you'll want to read how the Env Health Department answers.
It is horrifying and hilarious by turns.  Watch these waste meisters
try to make light of a facility so out of control it could shut down the 
power
grid to Southern California.  If any member of the public has tried to 
complain
about sludge you'll see that even if you are an attorney for Los Angeles 
Department
of Power and Water  you can't make a dent in the contentment and insouciance 
of
the so called sludge regulators....

Get your ticket to a ringside seat when Los Angeles Power and Water tries to 
explain
what is wrong at Nursery Products.

To read full minutes of the meeting:
www.ciwmb.ca.gov/Agendas/MtgDocs/2003/10/00012940.pdf

Nursery Products complaints start on electronic page 37

..........................................................................
Los Angeles Department of Water and Power
Presentation at California Integrated Waste Mangement Board
Meeting Oct 6, 2003
Re: Nursery Products of Adelanto California



I have David Hotchkiss, AssistantCity Attorney,
the City of Los Angeles;
Ronald Holst from  LA DWP;
and
William Spring from LA DWP.

MR. HOTCHKISS: Good afternoon. I'm David
      Page 38


Hotchkiss, Assistant City Attorney. And I want to maximize our
time here and be as coordinated as possible.  I'd first like to have Mr. 
Holst,
who's the  operating plant manager, speak to the specific issues that  have
arisen at the Adelanto facility.  Next I'd like Mr. Bill Spring, who is the
assistant general manager in charge of the power plant  operations, speak 
about
the potentials that are arising  because of the operations of this facility 
in
terms of the  western power grid.  And then finally I'd like to make a
cumulative  statement at the end.  Mr. Holst.

MR. HOLST: Yes, my name's
Ronald Holst. I'm the  electrical maintenance supervisor at the Adelanto 16
Converter Station and Switching Station. Nursery Products has severely
impacted our  facility since they've been there with the dust, the  odors,
and the flies. It's a health hazard and a safety  hazard for my people. My
people work in manlifts out in  the yard. And there are times when the odors
and the flies are so bad, their eyes burn, their noses run. I've  had to
buy mosquito nets for my people to work with, the 24 flies have been so bad. 
25
That's not very conducive to safe work practices.
      Page 39

It's also making a significant -- the dust and the debris  are
making a significant impact on our station. We're  engulfing dust and debris
into our cooling towers, into 4 our water system.  This facility is a major
part of the grid. It  just doesn't serve the City of Los Angeles. It serves 
the
Western System Circulating Council, because we put power  on the grid for
southern California. There's eight  500,000 volt lines that terminate in 
that
station, with a  capability of three to four billion watts of power. That's
enough power to serve probably four million people  and the businesses that 
go
along with them, including the  harbor city -- L.A.'s harbor and the 
airport,
everything.  We provide power off of the grid. Partners to  that facility
are Burbank, Pasadena, and Anaheim and  Riverside. So I represent not only 
my
people that are  being impacted, but all the citizens that are rate payers
that are getting power off of the system.  The dirt that is accumulating on
our high voltage  equipment -- at 500,000 volts, it's searching for ground.
When there's extreme amounts of debris, we can get  flashovers. We can get
flashovers from too much debris in  the air. We can get -- which blows
equipment up.  We have -- the power that we're getting comes  from all over
the southern transmission system. We have

      Page 40

two lines of DC, which is a million volts of potential between
the two of them, that bring dedicated generators  from Delta, Utah. I have
generally 1840 megawatts of power on those two DC lines -- just those two DC
lines.  If those pieces of equipment go down, we  immediately lose 1,800
megawatts of power. And when those  generators go off line, I got nowhere to
put it. I have  to try to reroute it and put it around the whole grid.  If 
you
guys and this Committee allow this thing  to become ten times bigger, it's
going to have a dramatic  effect on that station. It's already impacting the
station incredibly right now. But if you make it ten times bigger, it's
going to really hurt the reliability of  that station. The reliability of 
that
station is  intricate to the western grid. Thank you.

CHAIRPERSON
PAPARIAN: I think we have -- we might have a question before you leave.
MR. HOLST: Sure.

CHAIRPERSON PAPARIAN: Mr. Jones and then Mrs.  Peace.

COMMITTEE MEMBER JONES: Thanks, Mr. Chair.  Do you have practices and
procedures to get dust off of your system normally?

MR. HOLST: Yes, we do.
But some of this

      Page 41

equipment, like the 500 DC lines, I can only take out once  a
year. And I take out half of it for two weeks and I take the other half out
for two weeks. That's it.

COMMITTEE MEMBER JONES: There's no external way to
do -- what do you do when the Santa Ana's are blowing?

MR. HOLST: The station
was built for the normal  desert dust. It was engineered for that. Not the
increase of this facility. This facility, with the dust from the traffic, 
the
compost material is coming on in the  air, it's blowing -- the dust devils
pull up in the air.  It puts it all over my whole facility. It sucks it into
the intake of my cooling towers. The cooling towers have  to cool the --
valves that change AC to DC. All that stuff takes increased maintenance.

COMMITTEE MEMBER JONES: But when the Santa Ana winds are blowing, do you 
shut your plant down?

MR. HOLST: No, sir.

COMMITTEE MEMBER JONES: So your plant
can handle the Santa Ana -- I used to run the landfills in that county. I
have a pretty good idea about what that wind is  like.

MR. HOLST: Yes, sir.

COMMITTEE MEMBER JONES: And I'd also run some composting facilities. And
there's no comparison ¡V

MR. HOLST: I can tell you right now that there


      Page 42
is a significant increase on my converter station  bushings,
through-the-wall bushings as well as my  transformer bushings.

COMMITTEE
MEMBER JONES: I don't doubt that there isn't an increase in there. There 
could
be an increase.  I don't know what the source of that increase is until I  
go
down and look.  But what I'm asking -- it's almost -- I almost had a sense
that this is almost like preventative  maintenance, this -- all of a sudden
they have 125 people  objecting to it, considering they were informed by
letters that were passed around by power and water employees.

MR. HOLST:
Those people need help. They're not  getting any help from their government
agencies. Okay?  They don't know who to complain to. They do not -- they
were not notified that this facility was even coming in  there. And if you
make it tenfold, it's going to very  much impact their lives and their
businesses. It's going  to impact ours, I'm telling you.

COMMITTEE MEMBER
JONES: Okay. And we have to  look at the mitigations, that needs to happen.
But I'm really -- still want to get an answer as to: During the  Santa Ana
winds how much of a dust load is on your system?  I mean what is it
comparative to what your daily stuff is now?

      Page 43
  MR. HOLST: I don't quite understand. There's a significant
amount of dust. Okay?

COMMITTEE MEMBER JONES: From the Santa Ana's?

MR.
HOLST: From the Santa Ana's.

COMMITTEE MEMBER JONES: More or less than what's
coming off of this facility on a daily basis?  I'm trying to put this --
you're telling me the  world's going to end. And I'm trying to figure out ¡V

MR. HOLST: I'm not telling you that the  world's ¡V

COMMITTEE MEMBER JONES:
ƒÞ	I'm trying to figure  out what ¡V

MR. HOLST: -- going to end. I'm
telling you  that there's going to be a significant increase to the  risk to
the power system. With all that dirt in the area we have much more potential
for flashover. I don't know what's in the ¡V

COMMITTEE MEMBER JONES:
Right. And so my question was, what are your normal maintenance procedures
for just ancillary dust that's sitting on your lines or in that area? Do you
blow them down? Do you -- you know,without having to take the whole system
down, is there a maintenance program --

MR. HOLST: The AC part of the yard
we can wash  hot. Some of it we can get out -- isolate to get out.

      Page 44
To clean the DC side, pretty much stays as it is  till March of
every year when I can get to it. And it's not that I can't get it. It's that
it doesn't go down.  Those generators are cranking power.

COMMITTEE MEMBER

JONES: Sure. It's the normal  time. I gotcha.

MR. HOLST: And we have
protective coating on the converter transformers to help with the dirt. I 
sent
pictures to the manufacturer that makes the coating for  those transformers
to increase the dielectric strength of  them for the material that's on 
them.
And when I sent  them the pictures of them, they told me that there is a
limit to what -- how much that dielectric coating can do.  Okay?

COMMITTEE MEMBER JONES: Okay.

CHAIRPERSON PAPARIAN: Mrs. Peace.

COMMITTEE MEMBER
PEACE: I guess my question was -- the Board issued this composting permit to
Nursery Products in February of 2002. Did you notice the increased dust
problem and fly problem right away? Or is this just something that's gotten
worse the last couple  months?

MR. HOLST: After they -- no. After they
started  putting their material in is when we started noticing the
significant difference.

      Page 45

They had more trucks in there. They had  equipment moving
around. The smell was immediate when  they started putting the bio-solids in
there with the  green waste. And the flies came right away. And at the  
start
they were overwhelming. I don't know if you have  pictures of what I took of
pictures of the flies around my  facility. I mean that's the kind of stuff 
my
people are  trying to work in. And our safety regulations -- it's 11  feet 3
inches we have to be away from the equipment. And when they're so engrossed
by swatting flies and their eyes are burning and their noses are running 
from
this compost  material, they're not paying good attention to what  they're
doing.  It doesn't take much of a mistake at 500,000  volts to kill
somebody.

COMMITTEE MEMBER PEACE: And are the flies bad all year round or
is it just certain times of the year that they seem to be worse or is it --


MR. HOLST: The flies were really bad after the first of the year. They got
a little bit better. And when the weather started cooling off and the fly
season is  supposed to be going down, it heated up again. And the stink and
the flies came right back.  I've been spraying our facility every two to
three weeks around the buildings to try and keep the flies

      Page 46
people -- support people to come in on my facility to do  down
and away from the buildings, because even the  buildings get flies in them. 
You
can't drink a cup of  coffee in my office without having two or three flies 
in
your cup of coffee. I mean it's just -- it's awful. I  used to talk on the
phone with one hand and have a fly  swatter in the hand -- in the other.
People come to our facility. I have outside  work for us, other than from 
the
Los Angeles Department of  Water and Power. They don't even want to come
because the working conditions are so bad. That's their job and they don't
want to come. Out-of-town work is voluntary. The situation -- if you guys
approve this and  make it ten times bigger, we're going to have big
problems. We're going to have labor issue problems.  We're going to have
reliability problems. The reliability  affects all of our rates. Rates are
based on reliability.

COMMITTEE MEMBER PEACE: Thank you.

CHAIRPERSON
PAPARIAN: Okay. Thank you.

MR. SPRING: Hi. My name is Bill Spring. I'm the
Assistant Director of the Power Supply Operations Business Unit for the
Department of Water and Power. Our concern from a management point of view 
--
and I know our general manager sent a letter to the Board here expressing
the Department's concern -- is as Ron
(

      Page 47


says, approximately two million watts of power flow across the
DC line from Delta, Utah, and enter -- and then the associated AC
switching yard that Ron talks  about supports another 2,000 -- or two 
billion
watts.
So basically about four billion watts of power  flowed through this
facility. The failure of this facility catastrophically could result in
blackouts and/or  something akin to what happened in New York if our
equipment didn't work right.  Now, there's also the equipment that we need 
to
have work also with PG&E and Southern California Edison  and San Diego Gas
and Electric.  So we're real concerned about the impact that  this Nursery
Products composting facility is having on our  ability to serve our 
customers
as well as the people in  the western United States. I'm not sure whether 
you
realize, but the whole electrical system in the western United States is
tied together.  So that somewhat happened in New York as things  cascaded
throughout the system.  Now, we have a much better system here, and we
don't expect that to happen. But we are concerned about the loss of four
billion watts at one time on the ability of the system to respond to that
kind of a problem. We have tried to work with Nursery Products and

      Page 48
talked to them. And they assured us they were looking for
another facility to relocate their composting. But I  guess they haven't 
been
able to locate one. We didn't expect them to be asking to increase the size 
of
the  facility by tenfold, and that does really concern us.  Certainly, Mr.
Jones, we can do more and more maintenance, which is going to cost money. I
suppose the  Department has the money. Although we would prefer not to  have
to do the additional maintenance.

We did design the  facility to withstand the
environment that it was located 11 in years back when we spent over $170 
million
on this facility.  So we're really concerned that we get some kind  of
resolution to this problem. We want Nursery Products to not expand their
facility and work on relocating.  As you said, we have queried the people in
the community to let them know of what's going on here. Most  of them are
small businesses that were unsure as to where they would raise their
concerns, and that's why we were  the advocate to show them where they could
send their  concerns to. We freely admit that. Basically we would like to
see at least this  current permit expansion to be halted until we have a
chance to explore alternatives with Nursery Products.  Thank you.

      Page 49


CHAIRPERSON PAPARIAN: Any questions?  Mr. Jones.

COMMITTEE
MEMBER JONES: I understand your stuff,  but I just -- I always worry about
people that just want  to, you know, draw a line in the sand. And so the 
fact
that you want to work with them, that -- I mean it's a little glimmer of 
hope
for me.  What do you do -- I mean you got power lines all throughout 
southern
California. So you have tree trimmings and all these other things. I know
you've got -- you're dealing with the bark beetle death issues. Is that
material getting ground up and going to composting facilities, or is it all
going to landfill or land  application?

MR. SPRING: You mean what we do --

COMMITTEE MEMBER JONES: -- when you maintain  under your lines and --
MR. SPRING: -- when we're tree trimming in the  city?

COMMITTEE MEMBER
JONES: Yeah, as you maintain  around your lines, some of your lower lines 
and
things  like that.

MR. SPRING: Actually, Mr. Jones, a lot of the
material that's going into Nursery Products is coming out
of the City of Los
Angeles. It's stuff that's not going

      Page 50
into the landfill that we are recycling through a composting
program. We have not only this facility but other facilities that the city
sanitation department deals with.

COMMITTEE MEMBER JONES: We were given a
report  last Board meeting about issues with you folks, Southern Ed, and a
lot of other things about the bark beetle death  and the amount of trees 
that
are going to start coming down. And I think you guys were cranking up your
efforts even more so to get them away from the houses and stuff  that you
serve or near where you serve. But most of that material's going to
composting facilities?

MR. SPRING: As far as I know. I'm not  completely
familiar with that program because that's in  our distribution section 
mainly.
Although the high voltage lines don't usually have anything growing on them.


COMMITTEE MEMBER JONES: Or under them.

MR. SPRING: Or under them, right.
But I'm  pretty confident that we have -- as the City of Los Angeles, we
are committed to recycling. And I'm sure that  we do move a lot of that
product into composting facilities rather than into the landfill.

COMMITTEE MEMBER JONES: Thanks.

CHAIRPERSON PAPARIAN: Have you looked at


      Page 51
possible mitigation measures that the operator can take at  the
existing location?

MR. SPRING: Well, as Mr. Holst said, you know, the
facility was designed to take the environment where  it's located.


CHAIRPERSON PAPARIAN: No, I don't mean your facility. I mean the composting
facility. Have you  looked at -- would you recommend any additional 
mitigation
measures? Is there anything you're aware of that could help mitigate the
impacts you're concerned about through actions that they could take?

MR. SPRING: Well, we've cooperated with them. We've used our vector control 
and
they've used some kind of vector control to keep the flies down. That seems
to be a losing battle.  The dust mitigation. We've come to agreement
that they would put water on the roads going in and out of  there. But we 
fail
to see that that's being done. A number of things that they've agreed to do
to mitigate  this don't -- either they're not doing it or it doesn't seem
to be working.

CHAIRPERSON PAPARIAN: Okay. Anything else? Thank you.

MR. SPRING: Thank you.

MR. HOTCHKISS: Good afternoon.  Again I am David

      Page 52

Hotchkiss, Assistant City Attorney.

Mr. Paparian,
to address your question, based  upon the reading I've done and the research 
I've done in
the situation, it appears that the only thing that could protect the City of
Los Angeles's Adelanto Converter and  Switching Station from the potentials
that we're talking  about today, that is, flashover and resultant fire or
electrocutions that might occur in the existence of flashover, would be to
encapsulate this facility, meaning that you would have to separate the
facility from the  environment that surrounds it. And in terms of the
offensive orders that's being propagated there, they would have to put in
some kind of a filtration system, which is common in the Ohio Valley and
other places where these  type of facilities are operated. But that of
course appears to be an  insurmountable expense on a 40-acre site. But 
that's
just 18 from my perspective. I'd like to talk just for a few minutes about
the 20 community that this exists in, not just our 40 workers who 21 are on 
the
plant, which is separated by Pansy Road from 22 the Nursery Products 
facility.
We are one small city street separated with $170-some million switching and
converter station, which is absolutely integral to the electrical grid in
the western United States.


      Page 53

We have people who historically were able to work out of doors
and work on these facilities day in, week after week, without any kind of
protective clothing at  all. Now they're going out into the field wearing 
bee
keeper hats to keep the flies out of their noses, out of their eyes. Now,
I've gone through the permit that was  previously issued in this matter. And 
I
note in particular that they were required under the permit to not allow
any vectors, to have any offensive noises emanating, and to keep dust 
control
to an absolute minimum under the existing permit. They haven't lived up to
their existing permit. The physical evidence that we've put before you
and the points that have been made by Mr. Holst make it graphically clear
that not only our employees, but -- but when we canvassed the people in the
community who said to us, "We didn't know where to turn," we called the City
of Adelanto's manager -- the city manager, and he referred us to the
Nursery Products organization to get help. The city couldn't help them. The
county has been unable to help them. And we, the switching station, pay  $2
million a year in taxes to the County of San  Bernardino, and it has been 
able
to do nothing to  facilitate a remedial action in this situation.


      Page 54
Now, I think the most graphic thing that I've read today --
because I have received these reports at the same time you did -- was the
report of Melva Davis, who is  the principal of the public school in this
immediate vicinity. And if you'll give me a moment, I'd like to read this
into the record. She says, "The odor and fumes from the company are
seriously strong. There are days when the smell is extremely foul. Students
complain of headaches and  stomachaches. We are infested with flies. It is
often  difficult to guarantee that foods served in our school cafeteria are
healthy for our students and staff. Because we have preschool through 8th
grade students we cannot spray to eliminate the flies. Our primary concern 
is
the  safety of all the students, parents, and staff. Thank you for this
opportunity to voice our concern." These people have had no prior
opportunity, no  real opportunity to voice their concern. And as I went
through all of these reports that I received today, there were property
owners, business operators, people who have been suffering under this thing 
for almost a year now with no avenue for relief from these ongoing flies
and obnoxious odors. And of course in our situation we're hyper-concerned
about the dust. But we're also concerned about the noxious odors.

      Page 55
I mean this is a classic public nuisance situation. And we're
merely asking this Board not to increase the nuisance, but certainly to do
something about encapsulating this facility to make sure that the odors and
the flies and the dust do not come on to our facility. Because if they
continue to come on to our facility ¡V

I think Mr. Holst is correct. From
everything I've read about the potential for flashover, it is real, it is a
serious problem, and it is a problem that needs to be addressed sooner 
rather
than later.  If you have any questions on the legal side of  things, I'll be
happy to address those.

CHAIRPERSON PAPARIAN: I've got a couple quick
ones.  Now, we have the local enforcement agency for San  Bernardino County.
Has the DWP been contacting them, complaining to them? What kind of response
do you have --

MR. HOTCHKISS: We have been in contact with the LEA since
the very beginning of the problems arising, which was early in January of
this last year. And I've  looked at some of the LEA reports. And one of 
them,
which stuck way out in my mind, was a finding of no violation. Then it
says that the putrid or bad odors are going to be corrected by the
application of some kind of odor-controlling device, without mentioning what
it was.

      Page 56
So in the presence of an investigator you have these offensive
foul odors permeating the atmosphere. They find no violation under the 
permit.
They should 4 have. And they say that "We're putting this back on Nursery
Products to deal with the odor," but no violation. Now, that has been a
consistent pattern in this situation. No agency called in to look at this
problem has taken any 8 action against this facility. Why? I simply do not 
know.  I should also point out for the record, in going through the new 
proposed
permit, it states that the City of Adelanto Fire Station has announced that
it has met or meets all necessary requirements.

The City of Adelanto does
not have a fire station. There is a county fire department there. And our
interviews with the county fire personnel, which is directly across the
street from our facility, goes as follows: There is no water -- there is
no water at this facility. There is one fire hydrant at the end of a run on
Pansy Road at the corner of a 40-acre parcel. Okay? No water on the 
facility.
No electricity on the facility except the solar panel over the trailer
that works as the composting facility office. Okay? So the fire personnel
have told our people upon interview that if a fire started there, there 
would
be no way to control the fire. They would suck that pipe dry with one
single pumper. To control a 40-acre potential

      Page 57
fire? It's impossible. If a fire starts there and
noncombustible vapors come over, carrying carbon and other  byproducts from 
the
fire, and they blow right on to our facility, you're going to be seeing huge
flashovers to ground. It's an intolerably dangerous situation to continue
the operations and the status quo there. Is there anything else?

CHAIRPERSON PAPARIAN: Any other questions? Mr. Jones.

COMMITTEE MEMBER JONES: No, I'll
save mine  for -- I do have questions for the LEA. I'll tell you,  I'm
amazed.

CHAIRPERSON PAPARIAN: Let me just ask you one other thing.

COMMITTEE MEMBER JONES: Not with the LEA. Go ahead.

CHAIRPERSON PAPARIAN:
You may not have gotten this far. But we have some restrictions on our
ability to deal with permits once they've gotten this far. You're
suggesting that we turn down this permit.

MR. HOTCHKISS: I think that the
permit should be modified to require encapsulation and filtration at that
place. I'm not seeking to put them out of business. I think they're entitled
to run their operations, but not at

      Page 58
the expense of little children playing in the school yard and
not at the expense of everybody else who lives and works in that community. 
I
think it should be encapsulated and they should filter out the foul air.

CHAIRPERSON PAPARIAN: Okay.

COMMITTEE MEMBER JONES: I do have a question
when you're done.

CHAIRPERSON PAPARIAN: Just a second.  Okay. Let me just ask
something on a slightly different topic. Mr. Spring mentioned that there's
been some work with the applicant to see about getting them relocated.

MR.HOTCHKISS: That's correct. And I've been a part of that.

CHAIRPERSON PAPARIAN:
Yeah. So I would assume, given some of the property holdings you
guys have, you may be looking at some of those too or -- can you -- are 
there
places that you have that you guys can offer as an alternative site, or
are you aware of alternative sites?

MR. HOTCHKISS:
Well, the City of Los Angeles certainly has property holdings, most of them 
in the Inyo-Mono Basin area.

CHAIRPERSON PAPARIAN: All right.

MR. HOTCHKISS: Our property
in the desert area around Adelanto, I believe this is the only property that


      Page 59
we hold out there, plus the right-of-ways for the power lines
that come in and go out. But if they want to relocate in the Owens Valley,
then we do have property there certainly.

CHAIRPERSON PAPARIAN:     Do you feel
like -- okay. Regardless of whether it's your property or somebody else's
property, do you feel like there's some potential there for their 
relocation,
or it's just something you guys would like to have happen?

MR. HOTCHKISS:
I speak only on behalf of one of the property owners and operators in this
community. But I also feel compelled, on behalf of those who are not here
with a mouthpiece to stand in front of you, to say that, without a doubt,
having reviewed all hundred and -- whatever it was -- twenty some reports
that were sent out from these various folks, that the vast majority of them
said, "Please get it out of our community." And that's what we're saying,
please get it out of our community. And then, on the alternative, if they
could encapsulate this thing, cover the windrows and somehow control the
odor and flies, I don't think we'll have a problem being neighbors with 
these
people. But I just don't see it happening. It hasn't happened in the last
nine months.

CHAIRPERSON PAPARIAN: Okay. Thank you. It's possible we might
have some additional

      Page 60
questions after -- I think we're going to hear from the  LEA.
The LEA, are you here?  Yes.  I'm sorry, Mr. Jones. You have a question for
the LEA?  Do you want to respond first? And then I think several of us might
have some questions about what's going  on there. Or do you want us to just
dive into questions?

MS. ADAMS: I would be happy to answer your questions.
I'm Jackie Adams with the San Bernardino County LEA.

CHAIRPERSON
PAPARIAN: Okay. Mr. Jones.

BOARD MEMBER JONES: Ms. Adams, how often do you
inspect this facility or does your staff inspect it?

MS. ADAMS: We inspect the facility monthly.

COMMITTEE MEMBER JONES: Okay. And in the last --
there was no violations through 2002 and no violations through 2003, is that
--

MS. ADAMS: That's correct.

COMMITTEE MEMBER JONES: Okay. Odor issues --
the new regs call for an odor minimization plan. And I'm  assuming that's
one of the reasons for this permit revision....

go to PDF file to read on......
http://www.ciwmb.ca.gov/Agendas/MtgDocs/2003/10/00012940.pdf

pick it up on electronic page 61

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