SITE INFORMATION AND CORRESPONDENCE

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REVISED CWC SECTION 13308 TIME SCHEDULE ORDER NO.R5-2002-0014 • -2- MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY SAN JOAQUIN COUNTY 9. The WDRs limit the wastewater flow to land to 500,000 gallons per day(gpd). However, a review of the self-monitoring reports from January 2001 through September 2001 shows that daily flow discharged to land ranges from 8,610 to 1,616,927 gpd, and that the permit limit was exceeded 47% of the time. 10. The January 2001 through September 2001 self-monitoring reports show that the total dissolved solids (TDS) concentrations in the wastewater ranged from approximately 2,500 to 5,600 mg/1. Dissolved Inorganic Solids (DIS) concentrations ranged from 800 to 3,700 mg/l, with an average concentration of 2,400 mg/1. These values exceed both the yearly average and daily maximum DIS loading limits contained in the WDRs. Sodium and chloride are also present at elevated concentrations in the wastewater. Sodium has been reported at average concentrations of approximately 864 mg/l; chloride has been reported at average concentrations of approximately 557 mg/l. 11. The Discharger's facility is on approximately 280 acres, of which approximately 200 acres are available for land application of process wastewater. Wastewater is currently spray irrigated to land containing mainly volunteer weeds and grass. The WDRs require that a crop be grown on the disposal land, but the Discharger did not begin planting a crop until 2001. In correspondence dated 15 January 2002, the Discharger reported that, since October 2001, approximately 50 acres of land has been planted to oats or winter wheat. Approximately 75 of the 200 acres are currently cropped. Because wastewater is applied to the land application areas at rates greater than can be used or disposed of by percolation and/or evapotranspiration, a significant amount of tailwater is generated. 12. The Discharger has stated that approximately 350 employees work on-site. Based on San Joaquin County Environmental Health Department (SJCEHD) records dated 25 October 2001, the facility is served by a septic tank that was sized for 164 employees. The records indicate the septic tank effluent discharges to eight, 95-feet long leach lines that are equipped with 25-feet deep seepage pits at the ends. The Discharger recently began applying industrial wastewater to the land over the leach lines. This will likely reduce the infiltration capacity of the soil and may impact the underlying groundwater quality. VIOLATIONS OF THE WASTE DISCHARGE REQUIREMENTS 13. A 2 November 2001 inspection of the facility and land application areas, as well as a review of the case file, revealed numerous violations of the WDRs. On 30 November 2001 a Notice of Violation was transmitted to the Discharger. The violations of the WDRs are summarized below: a. WDRs Finding No. 5 limits the wastewater flow rate at 500,000 gallons per day. Bet,,nen January 2001 and September 2001, the Discharger has exceeded the flow rate 47% of the time. Additionally, the Discharger has failed to accurately monitor the flow rate using a meter. b. WDRs Findings No. 5, 7, and 17 limit the wastewater application to cropped areas. The Discharger has failed to plant crops on most of the land application areas. The small areas that have been cropped show severe plant tissue damage. c. WDRs Prohibition No. A.1 prohibits discharge of wastewater to surface water drainage courses. The Discharger has routinely used surface water drainage courses to convey wastewater. Two berms have been installed across the surface drainage to control tailwater