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WASTE DISCHARGE REQUIR&tNTS ORDER NO. GOLDSTONE LAND COMPANY,LLC AND KURT KAUTZ BEAR CREEK WINERY SAN JOAQUIN COUNTY b. The waste discharge requirements implement the Basin Plan and allow discharge only in accordance with the Basin Plan; and c. The wastewater is nonhazardous waste and need not be managed according to Title 22, CCR, Division 4.5, Chapter 11, as a hazardous waste. ANTI-DEGRADATION ANALYSIS 62. State Water Resources Control Board (State Board) Resolution No. 68-16 (hereafter Resolution No. 68-16)requires that waste be discharged in a manner that maintains the high quality waters of the state. Any change in quality can occur only after full application of BPTC of the waste, and must be consistent with maximum benefit to the people of the State, not unreasonably affect a beneficial use, and not result in water that exceeds a water quality objective. Where the water quality objective is exceeded in background water quality but nonetheless beneficially used or designated for beneficial use, the background water quality cannot be degraded. 63. Antidegradation factors have been considered pursuant to Resolution No. 68-16. The project as proposed may degrade groundwater with dissolved solids and possibly create nuisance odors from organics if waste is ponded when applied to land. Groundwater conditions are not adequately defined because none of the existing groundwater wells are clearly downgradient of the existing 12-acre LTU however some degradation is apparent in the well partially downgradient (Well MW-3) of the existing LTU. Degradation of the groundwater with dissolved solids is not consistent with maximum benefit to the people of the State. If it were, the Discharger would have to demonstrate its treatment as being BPTC. The Discharger has made no BPTC demonstration. In short, the project as proposed by the Discharger is not consistent with Resolution 68-16. 64. In considering potential dissolved solids degradation of groundwater from the discharge, the salt already within the LTU and underlying soil profile must be considered, and elevated salt is already within the LTU and likely in the soil profile below it, given past practices of the Discharger. Given the unacceptability of the salt proposed for discharge, it is not necessary to quantify this factor. GROUNDWATER DISCHARGE ANALYSIS—LAWS,RULES,AND REGULATIONS 65. For the identified waste constituents present in the discharge in significant concentrations, the water quality objectives determined by the translator process from narrative objectives are all higher than the observed background water quality, except for TDS and nitrate. Where background water quality is unaffected by other discharges and greater than water quality objectives, the background water quality establishes the water quality limit. Within the San Joaquin Valley, the salinity of the groundwater has been degraded through years of agricultural operations. At this facility, there does not appear to be a direct upgradient source of the salinity; therefore, the background water quality value for TDS becomes the governing water quality objective. 66. The general concentrations of key waste constituents in the wastewater applied to land compared with groundwater and water quality limits are as follows: V:\.Jo .m NmISISutMbeimliPropn Filcs CrceNWDK.