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ORDER NO.R5-2003-0099 4 INFORMATION SHEET NEWPORT PACIFIC CAPITAL COMPANY ARBOR MOBILE HOME PARK WASTEWATER TREATMENT FACILTY SAN JOAQUIN COUNTY The Title 27 zero leakage protection strategy relies heavily on extensive groundwater monitoring to increase a discharger's awareness of, and accountability for, compliance with the prescriptive and performance standards. With a high volume, concentrated, uncontained discharge to land, monitoring takes on even greater importance. Title 27 regulations pertaining to groundwater monitoring and the detection and characterization of waste constituents in groundwater have been in effect and successfully implemented for many years. No regulation currently specifies similar criteria more suitable for a situation where extensive infiltration into groundwater occurs. However, where, as here, such infiltration occurs, it is appropriate that the Title 27 groundwater monitoring procedures be extended and applied on a case-by-case basis under Water Code section 13267. The Discharger must monitor groundwater for representative constituents present in the discharge and capable of reaching groundwater and violating the groundwater limitation. The Discharger is required to install a network of groundwater monitoring wells to adequately characterize background water quality and potential groundwater impacts from the wastewater discharge. Due to cost considerations, the Discharger is not required to analyze the groundwater for every constituent that is present in wastewater. Instead, the Discharger is to analyze for representative constituents. If degradation is detected, then the Discharger would be required to fully define the extent of degradation, which would include analyzing the groundwater for other constituents (e.g.,boron, chloride, sodium, etc.) Reopener The conditions of discharge in the proposed Order were developed based on currently available technical information and applicable water quality laws, regulations,policies, and plans, and are intended to assure conformance with them. Additional information must be developed and documented by the Discharger as required by schedules set forth in the proposed Order. As this additional information is obtained, decisions will be made concerning the best means of assuring the highest water quality possible and that could involve substantial cost. It may be appropriate to reopen the Order if applicable laws and regulations change, but the mere possibility that such laws and regulations may change is not sufficient basis for reopening the Order. The CWC requires that waste discharge requirements implement all applicable requirements. Surface water drainage is to the Mokelumne River. TRO: 5/14/2003