SITE INFORMATION AND CORRESPONDENCE_CASE 2

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INFORMATION SHEET 7 ORDER NO. R5-2007- CITY OF TRACY AND LEPRINO FOODS COMPANY LAND DISCHARGE UNITS OF THE TRACY WASTEWATER TREATMENT PLANT SAN JOAQUIN COUNTY summarized in Finding 9 of this Order, the wastes contained in the unlined industrial ponds exceed the applicable water quality objectives for TDS. The Discharger has utilized the ponds for many years, so any assimilative capacity in the shallow groundwater basin has likely been exhausted. In addition, the depth to groundwater only ranges from 14 to 18 feet near the industrial ponds, so the soil column cannot be relied upon to provide attenuation of wastes. Therefore, if not properly controlled, the industrial wastewater will be classified as a "designated waste." Discharge Prohibition A.2 of this Order prohibits the containment of designated wastes in the industrial ponds to protect the beneficial uses of the groundwater. Provision E.3 of this Order provides a time schedule for the Discharger to come into compliance with Discharge Prohibition A.2., by either reducing the constituent concentrations in the ponds or by lining the ponds in accordance with Title 27 California Code of Regulations pond lining technology. Section 20210 of Title 27, California Code of Regulations, requires that designated waste can only be discharged to a Class I or Class II surface impoundment equipped with engineered lining and a leachate collection and recovery system. Exemption from Title 27 Does Not Apply. Pursuant to section 20090(b) of Title 27, California Code of Regulations, the discharge of wastewater to land, including but not limited to evaporation ponds, percolation ponds or subsurface leachfields, may be exempted from the State Water Board-promulgated provisions of this subdivision, as long as the activity meets, and continues to meet, all preconditions listed below: i. the applicable Regional Water Board has issued WDRs, reclamation requirements or waived such issuance; ii. the discharge is in compliance with the applicable water quality control plan; and iii. the wastewater does not need to be managed according to Chapter 11, Division 4.5, Title 22 of this code as a hazardous waste. The existing and proposed wastewater treated in the ponds is not in compliance with the water quality control plan, because the analytical data show that the wastewater exceeds the Basin Plan's chemical constituents objective for groundwater. An additional Title 27 exemption, section 20090(a), is provided for discharges of domestic sewage or treated effluent associated with municipal wastewater treatment plants provided that the discharge is regulated under WDRs or a waiver of WDRs and that the discharge is consistent with applicable water quality objectives. The wastewater treated in the ponds is primarily industrial from Leprino and does not comply with water quality objectives. As such it cannot be exempt from Title 27 requirements. The existing industrial wastewater treated in the industrial ponds, if not properly controlled, will be classified as a designated waste and must be controlled in accordance with Title 27 requirements. Biosolids Dewatering. The Facility currently utilizes sand-lined sludge drying beds to dewater biosolids, which allow supernatant to percolate to the groundwater. At this time there are no groundwater monitoring wells in the vicinity of the drying beds. In