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DRAFT [TENTATIVE] WASTE DISCHARGE REQUIREMENTS ORDER R5-2023-00XX 28 <br />FORWARD, INC. <br />FORWARD LANDFILL <br />SAN JOAQUIN COUNTY <br />Waste <br />Type <br />Constituent Unit 2018 2019 2020 2021 <br />Total <br />Nitrogen mg/kg 2,615 1,033 2,050 3,760 <br />TKN mg/kg 2,613 1,032 2,048 3,706 <br />TDS mg/kg 12,325 14,748 21,600 13,850 <br />97.Previous WDRs Order No. R5-2014-0006 required that the LAA area not exceed <br />the annual total nitrogen load limit of 300 pounds per acre, however the WDRs <br />allowed for a site-specific loading rate to be established by a Nutrient <br />Management Plan and approved by the Executive Officer. On 21 May 2015, the <br />Discharger submitted a Nutrient Management Plan to demonstrate site-specific <br />data that would justify an increase in nitrogen loading to the LAA for the cannery <br />waste operation. In response to exceeding the total nitrogen loading in 2015, on <br />27 June 2016, the Assistant Executive Officer issued a Water Code section <br />13267 Order for Technical Reports requiring the Discharger to submit a Cannery <br />Waste Land Application Area Compliance Plan to address nitrogen loading <br />exceedances. <br />98.As stated in Finding 59, CAO R5-2017-0703 was issued and required the <br />Discharger to address violations associated with the over-loading of nitrogen in <br />the cannery waste LAA. In April 2018, the Discharger submitted 2017 Nutrient <br />Management Plan that evaluated the cannery waste management program and <br />recommended best practices to limit nitrogen loading. One of the changes made <br />by the Discharger as a result of the updated plan was to stop land applying <br />cannery mud waste. <br />99.Based on an evaluation of the available analytical data for effluent and <br />groundwater quality, these changes have resulted in less nitrogen loading. <br />Concentrations of constituents in groundwater are now stable, decreasing, or <br />requires additional samples to be taken (see Finding 31). <br />100.Site and groundwater conditions for the Facility are discussed in Findings 34 to <br />46. <br />101.Under WDR Order No. R5-2014-0006, the cannery waste monitoring area was <br />monitored by AMW-1, AMW-7, AMW-13 and AMW-10. AMW-10 was abandoned <br />on 1 October 2018. AMW-31S was then used for groundwater monitoring. Under <br />these current WDRs, alternative shallow groundwater monitoring wells were <br />selected to better detect levels of waste constituents. The four shallow <br />groundwater monitoring wells are AMW-44, AMW-45, AMW-46 and AMW-14. <br />AMW-44, AMW- 45, and AMW-46 are considered downgradient wells and <br />located on the northern edge of the land application area. AMW-14 is a