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STAFF REPORT • • ADMINISTRATIVE CIVIL LIABILITY ORDER AND 8 REVISION TO THE CWC WATER CODE SECTION 13308 TIME SCHEDULE ORDER MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY SAN JOAQUIN COUNTY outcome, and prepare a Settlement Agreement. In addition, staff believe that the Discharger should concentrate on bringing its facility into compliance with its TSO instead of spending additional resources on completing an SEP. RECOMMENDATION REGARDING ADMINISTRATIVE CIVIL LIABILITY The Discharger's wastewater treatment and discharge system has proven to be inadequate and needs substantial modifications. Staff has attempted to work voluntarily with the Discharger, and when that was unsuccessful, attempted to resolve the issues through a Cleanup and Abatement Order. Although the Discharger has made some improvements, the storage and discharge capacity improvements have not been completed and the Discharger remained in noncompliance with its WDRs and the C&A between 17 November 2000 and 25 January 2002. The Discharger has stated that it will pay the ACL Complaint as long as a portion of the payment can be used in a SEP. However, an SEP is inappropriate in this case. Therefore, staff recommends that the Regional Board adopt the $150,000 Administrative Civil Liability Order as proposed. TIME SCHEDULE ORDER REVISION On 5 April 2002, the Discharger submitted a request for a short-term increase to the flow limits included in TSO No. R5-2002-0014, stating that the increase is necessary for the company to remain economically viable. The Discharger's WDRs do not contain a flow limitation, although there are several findings stating that wastewater flows to land will not exceed 500,000 gallons per day (gpd). However, per the Discharger's requests in January 2002, the TSO contains a seven-day average flow limit of 600,000 gpd and a daily maximum of 750,000 gpd. These values are based on the Discharger's average flow data from 2001. The Discharger in now requesting that the TSO be revised to allow higher flows, to a seven-day average of 820,000 gpd and a daily maximum of 950,000 gpd. The written request was accompanied by an agronomist's report that presented a water balance for the period April to September 2002. Assuming maximum evapotranspiration in the land application areas, the water balance indicated a surplus of wastewater in April and insufficient wastewater from May to September. The report indicated supplemental irrigation water would be required to sustain full cropping production, or alternatively, fewer acres could be planted. The Discharger also requested authorization to spray the wastewater for dust control on approximately 3.5 miles of dirt roads and to use —"wastewater for compaction needs during*dowWction of the new storage reservoir. Staff reviewed the report and in a 1 May 2002 letter, requested additional information on a number of items, including proposed loading rates for BOD, nitrogen, and DIS. On 14 May 2002 the Discharger submitted a supplemental report to clarify items in its request for an increase in its flow limitation. While a number of items were clarified, staff are still concerned about the following: • Based on a yearly application rate of 48 inches of wastewater (1.3 million gallons per acre),the DIS loading rate is anticipated to be approximately 16 tons per acre. The total dissolved solids (TDS) loading rate will be even higher.