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INFORMATION SHEET 6 <br /> ORDER NO. R5-2007- <br /> CITY OF TRACY AND LEPRINO FOODS COMPANY <br /> LAND DISCHARGE UNITS OF THE TRACY WASTEWATER TREATMENT PLANT <br /> SAN JOAQUIN COUNTY <br /> October-December. This is likely the result of the increased EC concentrations in the <br /> ponds in late summer and fall. <br /> During an inspection of the Facility on 17 May 2004, Regional Water Board staff cited <br /> concerns of possible groundwater degradation due to unlined sludge drying beds and <br /> unlined treatment ponds. In addition, Regional Water Board staff raised concerns <br /> regarding the designation of the waste in the unlined ponds containing industrial <br /> wastewater from Leprino and the lack of best practicable treatment or control (BPTC) <br /> for the unlined sludge drying beds. On 15 June 2004, Regional Water Board staff <br /> issued a 13267 Order requesting a groundwater study to evaluate if groundwater <br /> degradation has occurred as a result of the sludge dewatering process, the sludge <br /> storage practices, and the industrial waste aeration process. No groundwater <br /> monitoring wells exist to evaluate degradation due to these processes. The 13267 <br /> Order also requested an evaluation of BPTC for the sludge dewatering and storage <br /> practices. Finally, the 13267 Order requested an evaluation of the classification of <br /> the industrial wastewater treated in the unlined ponds. <br /> In June 2005, the Discharger provided a groundwater study that only evaluated <br /> groundwater underlying the ponds using data from routine quarterly monitoring since <br /> 1990. It failed to evaluate if groundwater degradation had occurred as a result of the <br /> sludge dewatering and storage practices and the industrial waste aeration process, <br /> which was requested in the 13267 Order. <br /> The 2005 study evaluated the BPTC of the sludge drying and storage practices. The <br /> 2005 study concluded that the sludge drying beds needed to be paved to meet <br /> BPTC. However, other alternatives exist including dewatering using a belt filter press <br /> or a combination of paved drying beds and belt filter press. The 2005 study <br /> recommends the Discharger pave two drying beds and evaluate the effectiveness of <br /> the paved drying beds. After one-year of data collection, the Discharger could make <br /> a decision of the preferred BPTC alternative. <br /> The 2005 study also evaluated the industrial treatment process and determined that <br /> the industrial wastewater should not be classified as designated waste, pursuant to <br /> CWC section 13173. The 2005 study concluded, "The existing lined industrial <br /> pretreatment ponds appear to comply with requirements for Class 11 waste <br /> management units as specified in Title 27. Facultative ponds also appear to comply <br /> with the intent of Title 27 based on the fact that up to 3 feet of free board is available <br /> under normal operating conditions and groundwater is not being adversely impacted <br /> by the operation." <br /> Waste Characterization. A "designated waste" is defined under CWC section 13173 <br /> as any "non-hazardous waste that consists of, or contains, pollutants that, under <br /> ambient environmental conditions at a waste management unit, could be released in <br /> concentrations exceeding applicable water quality objectives or that could reasonably <br /> be expected to affect beneficial uses of the waters of the state as contained in the <br /> appropriate state water quality control plan." Based on the data characterization <br />