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STAFF REPORT • 10 ADMINISTRATIVE CIVIL LIABILITY ORDER AND REVISION TO THE CWC WATER CODE SECTION 13308 TIME SCHEDULE ORDER MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY SAN JOAQUIN COUNTY one existing well near the surface impoundment. The existing well is part of the Title 27 ponds monitoring network and had been previously reported to be dry. The groundwater report is summarized below: • Shallow and deep groundwater zones were identified and groundwater flows to the north. Wells with shallow groundwater are in low land areas, typically in close proximity to the intermittent stream. Wells with deep groundwater are typically in higher topographic elevation areas. • The chemistry of the groundwater in the shallow and deep zones was reported to be distinctly different. Staff s evaluation of the data confirms the difference, with shallow zones tending to have higher concentrations of sodium, chloride, and total dissolved solids. • Based on one sample event, groundwater quality at the site is poor. However, there may be naturally poor quality groundwater, as indicated by wells located at the upgradient edges of land application areas. • Well MW-9 did not produce adequate groundwater for sampling and may require replacement. • Additional groundwater monitoring is necessary to determine whether the land application of wastewater has degraded the underlying groundwater. Current Violations,of the TSO Staff has received a number of odor complaints regarding the site. Staff conducted an inspection on 10 May 2002 and offensive odors were confirmed at the irrigation checks and the "diesel'pond. The odor constitutes a verified condition of offensive odors and is a violation of TSO No. R5-2002-0014. Based on the condition and use of the checks to evaporate wastewater, it is reasonable to conclude the numerous odor complaints staff received are accurate of site conditions. A Notice of Violation regarding this issue was transmitted to the Discharger on 20 May 2002. The TSO required that construction of the 114 million gallon storage pond begin by 1 May 2002. Although survey stakes have been placed, no earth had been moved as of 10 May 2002, and staff understand that as of that date,the US Fish and Wildlife Service had not given permission for construction to begin. Revised MRP Order No. 97-037 became effective on 1 January 2002. Staff recently reviewed the monitoring reports submitted for the time period 1 January 2002 through 31 March 2002 (the latest received to date). Numerous violations of the Revised MRP were found; these are also violations of the TSO. Each of the three monitoring reports included some, or all, of the following violations: The effluent was not monitored for BOD, total settleable solids, nitrate,total Kjeldahl nitrogen, or total coliform. The wastewater pond was not monitored for freeboard or dissolved oxygen. Wastewater stored in other ponds (i.e. Emergency pond or Diesel pond) was not monitored. For the land application areas, the loading rate for BOD and total nitrogen was not calculated. A map showing the land application area was not included. The analyte pH was not monitored in the stormwater.