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0 <br /> -9- <br /> STAFF REPORT <br /> ADMINISTRATIVE CIVIL LIABILITY ORDER AND <br /> REVISION TO THE CWC WATER CODE SECTION 13308 TIME SCHEDULE ORDER <br /> MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY <br /> SAN JOAQUIN COUNTY <br /> • The BOD loading rate is 671bs/ac•day. The loading rate is low enough that odors should not be a <br /> problem, as long as wastewater does not pond on the land surface. <br /> • The available nitrogen application rate of 428 lbs/acre on an annual basis is likely above the crop <br /> uptake rate, especially considering the poor crop health in some areas of the facility. In addition, <br /> liquid fertilizer is being injected into the irrigation supply line, resulting in an even greater nitrogen <br /> loading rate than is calculated using wastewater alone. The total nitrogen loading rate is unknown. <br /> 10 May 2002 Inspection <br /> On 10 May 2002 Regional Board staff inspected the land application areas and one-million gallon <br /> storage pond as part of consideration of the flow rate increase. The land application areas were in better <br /> condition than during the last inspection performed on 2 November 2001. It was noted that no <br /> application of wastewater was being performed during the inspection. The following observations were <br /> made: <br /> The land application areas were not as saturated and significantly less tailwater runoff was observed. <br /> • Evidence of cropping was noted in most or all of the land application areas. However, large portions <br /> of the 95-acre field had not produced crops or the crops were slow to grow. In addition, evidence <br /> that over-application of wastewater had occurred in the 95-acre field area was observed. The <br /> evidence consisted of saturated soil and poor crop health. <br /> • Crops had been cut and were drying prior to baling and sale in the 18-North field. Crops had been <br /> cut and removed from the land application areas at the Spur North and Evap North fields. The <br /> Discharger reported that all of the 220 acres available for land application had been cropped. <br /> • At least two feet of freeboard existed at the one-million gallon storage pond. The pond also <br /> contained new equipment consisting of: a mechanical screen and rake, flow meters, pH and electrical <br /> conductivity meters, chemical fertilizer and surfactant feed system (into wastewater applied to land), <br /> and an experimental ion exchange treatment unit. <br /> • Offensive odors were noted at the east (downwind) side of the irrigation checks, despite the fact that <br /> these checks had not having received wastewater for substantial time. This constitutes a violation of <br /> the WDRs, C&A Order, and TSO. <br /> • The TSO states that construction of the 114 rmilion gallon storage pond was required to begi;aby <br /> 1 May 2002. On this date, the Discharger submitted a letter saying that construction had begun by <br /> the placement of survey stakes. Although staff saw some stakes in place, no other construction <br /> activity had taken place as of the date of the inspection, and the Discharger told staff that <br /> construction could not begin until certain issues were satisfied with the US Fish and Wildlife <br /> Service. In addition, the Discharger did not yet know the extent of the pond limits, so crops could <br /> not yet be planted in some of the fields surrounding the proposed pond location. <br /> Groundwater Considerations <br /> On 1 May 2002,the Discharger submitted a Groundwater Monitoring Well Installation, Sampling, and <br /> Analysis report which described installation of 13 groundwater monitoring wells and redevelopment of <br />