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Order No. R5-2009-0097 8 - Conditional Waiver of Waste Discharge Requirements for Small Food Processors and Small Wineries Within the Central Valley Region systems is far less than is required by this Order, and discharges to septic systems pose a higher threat to groundwater quality than a well-managed land application and waste recycling program. Although treatment technology is available to reduce the mass of BOD and nitrify/denitrify the wastewater, the capital and operation/maintenance costs of such advanced treatment systems would likely be infeasible for the majority of small businesses that will be regulated by this Order. Experience with numerous larger food processors in the Central Valley Regional has shown that the BOD and nitrogen content of the waste can be adequately reduced by a well-managed land application/recycling program to prevent significant groundwater degradation, even in areas where groundwater is very shallow. Therefore, the economic benefits derived from this low-cost, streamlined form of regulation support allowing limited, localized groundwater degradation as long as the terms of the Basin Plan are met. 33. Based on the above, this Order is consistent with Resolution 68-16 because it includes specific requirements and conditions of discharge that will minimize water quality degradation. Dischargers regulated under this Order are subject to enforcement action for any violations, and coverage under the conditional waiver can be terminated if the requirements and conditions are not met. 34. The Basin Plan's Antidegradation Implementation Policy states "Pursuant to this policy, a Report of Waste Discharge, or any other similar technical report required by the Board pursuant to Water Code Section 13267, must include information regarding the nature and extent of the discharge and the potential for the discharge to affect surface or ground water quality in the region. This information must be presented as an analysis of the impacts and potential impacts of the discharge on water quality, as measured by background concentrations and applicable water quality objectives. The extent of information necessary will depend on the specific conditions of the discharge. For example, use of best professional judgment and limited available information may be sufficient to determine that ground or surface water will not be degraded. In addition, the discharger must identify treatment or control measures to be taken to minimize or prevent water quality degradation." Dischargers submitting a Report of Waste Discharge to apply for coverage under this Order are not required to include a detailed site-specific analysis of the waste, groundwater conditions, or potential water quality impacts. As noted above. the character of food processing wastes is well-documented in the literature and Central Valley Water Board records. However, the Report of Waste Discharge technical information form developed for this Order requires complete disclosure of sufficient information about the operations of the facilities that will generate the waste to allow Central Valley Water Board staff to use best professional judgment to determine whether additional information is needed to show that the proposed discharge will be consistent with the conditions or this Order, and to determine whether coverage should hp. rimntarf