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STAFF REPORT • 0 ADMINISTRATIVE CIVIL LIABILITY ORDER AND 12 REVISION TO THE CWC WATER CODE SECTION 13308 TIME SCHEDULE ORDER MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY SAN JOAQUIN COUNTY • The Discharger has proposed applying wastewater as necessary for (a) compaction during construction of the new storage pond and for(b) dust control at both the construction site and on all 3.5 miles of the facility's dirt roads. The use of wastewater for compaction is appropriate, as is the application of wastewater to disturbed areas of the construction site to minimize dust generation; however, application of wastewater to all dirt roads is not a valid use and may create offensive odors, especially at the irrigation checks near the off-property residence. Staff propose that the TSO be revised to allow the Discharger to use wastewater for compaction needs during construction and for dust control only in areas disturbed by construction of the impoundment. The penalty would be $5,000 for each day in which wastewater is applied to dirt roads outside the active construction zone. • The Discharger recently installed a number of groundwater monitoring wells, but Well MW-9 did not contain enough groundwater to allow sample collection. This well is needed to monitor groundwater quality downgradient of a land application area and was part of the monitoring network proposed by the Discharger and approved by staff. If the well is not adequate to monitor the groundwater, it should be replaced. Therefore, another proposed revision to the TSO would require the Discharger to submit a report evaluating whether Well MW-9 is capable of being consistently used as a groundwater monitoring point. The penalty would be $2,500 for each day in which the report is late or incomplete. • Because the data from the single groundwater monitoring event is ambiguous as to groundwater quality, the Discharger needs to perform a second monitoring event and report the results in time for staff to incorporate the information into the tentative revised WDRs. The TSO has been revised to require the second sampling event, with results submitted by 31 July 2002. The penalty would be $2,500 for each day in which the report is late or incomplete. RECOMMENDATION The Discharger has made improvements to the land application areas that will allow a higher hydraulic application rate than what is presently allowed by the TSO. The higher application rate is appropriate for the summer of 2002 when evapotranspiration is higher. However, concerns about loading rates of dissolved solids, nitrogen compounds, and BOD exist. The BOD concern can be addressed with management provisions, and nitrogen can largely be addressed by improved cropping activities, but the DIS loading rate will require source control. The Discharger has performed some source control activities such as installing catch pans to collect high salinity wastewater and a new sump to divert-high salinity wastewater generated in the cannery, but it is anticipated that additional measures will be required in the future. Because this proposed revision of the TSO is of an interim measure, and reportedly necessary to allow the Discharger to remain in business while improvements are made, staff believe it is reasonable to allow the temporary increased flow rate until new WDRs can be considered by the Regional Board. However, it should be noted that recommendation of this interim flow rate increase does not guarantee a higher flow rate in the tentative WDRs. Staff will need to evaluate the RWD to see if a higher flow and loading rate can be sustained year-round without impacts to water quality.