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JUl_ 24 191 14: 58 FROM HOLLY SUGAR OPER PRGE . 003 Mr David Duncan -2- 19 July 1991 However, if the water table surface occurs in a clay layer, we would prefer to see well screens set in the next lower sandy zone, wherever possible. Water level measurements in the completed monitoring wells will be used to determine local ground water gradients. This exercise may be complicated by the proximity of the downg radient wells to the ground water mound that is ' likely to exist under the ponds and the southern background well's location adjacent to a water supply I well. If these factors confuse interpretation of _ ground water level data, we will ask for additional weUs in theme e__---- -- The data available in our files indicate that some or all of the wastewater streams from your facility have the potential to degrade water quality. Section 2522 of Chapter 15 defines "designated waste" as nonhazardous waste which consists of or contains pollutants which, under ambient environmen- tal conditions at the waste management unit, could be released in excess of applicable water quality objectives, or which could cause degradation of waters of the state. Section 2522 further states that designated wastes shall be discharged only at Class I or Class II waste management units_ For designated liquid wastes, Chapter 15 prescribes double-lined surface impoundments which afford complete containment of the waste. We understand that much of Holly's wastewater is currently used for irrigation. Holly needs to demonstrate that this practice constitutes a beneficial reuse of the water and not simply a waste disposal practice. If this demonstration cannot be made, then we will regulate this practice under Chapter 15. If Holly's wastewater has degraded water quality, it would be classified as a designated waste and the ponds would be regulated under Chapter 15. The ponds would need to be closed or upgraded to Class,II surface impoundment standards. As noted above, we believe that some or all of the facility's waste streams can be classified as designated wastes and therefore be regulated under Chapter 15. However, we intend to reserve our decision about the applicability of Chapter 15 to your facility until Holly submits the monitoring data and provides a technical report evaluating the facility's waste disposal practices in relation to Chapter 15. The monitoring data should be submitted to us as soon as it is available following monitoring well construction. The technical report should be submitted by 1 April 1992. The facility's 'waste discharge requirements (WDRs) have not been updated since 1971- The monitoring and reporting program which is part of the