SITE INFORMATION AND CORRESPONDENCE CASE 2

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STAFF REPORT -3- PAT MITCHELL AND CALIFORNIA NATURAL PRODUCTS LATHROP,SAN JOAQUIN COUNTY sampling was not initiated until May 1998;prior to that time samples were collected infrequently dating back to 1988. The data averaged below consists of between four to nine sample events. The facility data is averaged from one sampling event performed on 24 July 2000. A summary of the average analytical results is presented below: Land Application Area Facility Area Analytes Units MW1 MW2 MW3 Average A-C BOD mg/l 136 4.3 4.4 6.3 TDS mg/l 1,254 1,467 1,355 1,633 Fixed TDS mg/l 1,204 964 1,040 1,317 NO3 as Nitrate mg/l 154 168 135 203 Chloride mg/l 92 152 252 116 Potassium mg/l 3.4 3.4 4.8 7.3 Sodium mg/1 248 221 194 267 Elec. Cond. µmhos/cm 2,249 2,392 2,304 2,467 Waste Discharge Requirements The WDRs have been updated to contain all the recent standard requirements for facilities land applying industrial wastewater generated in food processing operations. The existing WDRs were adopted on 11 December 1998, it has been 26 months since the original order was adopted. The WDRs require the Discharger to install additional groundwater monitoring wells, conduct regular monitoring of the groundwater quality, limit the BOD and nitrate loading of the application area, and operate the land application area to maximize nutrient uptake and denitrification. Cropping activities are required in the application area and shall be sufficient to take up all the nutrients applied to the land application area. Comments Received Staff has met with the Discharger twice to discuss the WDRs and has reviewed 12 pages of written comments. Attached to the written comments are 22 pages of technical document references,data tables, and marked up pages from the tentative WDRs. After an objective review of the comments, staff has modified the WDRs to address some of the Discharger's concerns. However, significant differences still remain between the Discharger and staff. The major outstanding issues are discussed below. Staff were unable to accommodate most of the Discharger's substantial requests for changes to the WDRs;clarifications and minor wording changes have been accommodated. Staff have offered to continue to meet with the Discharger to explain our rationale for the WDRs requirements, and hope to resolve many of these issues. Those that aren't will be discussed during the staff presentation at the Board meeting.