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DRAFT [TENTATIVE] WASTE DISCHARGE REQUIREMENTS ORDER R5-2023-00XX 34 <br />FORWARD, INC. <br />FORWARD LANDFILL <br />SAN JOAQUIN COUNTY <br />Table 13—Data Comparison <br />Constituent <br />Effluent <br />(Rinsate, <br />mg/L)1 <br />Effluent <br />(Residuals, <br />mg/kg)2 <br />Downgradient <br />Groundwater <br />(mg/L)3 <br />Potential WQO <br />Reference <br />TDS 15,050 14,221 545 <br />500 mg/L /1,000 mg/L <br />(sMCL/sMCL upper) <br />Nitrate as N 347 2,138 8.8 10 mg/L (MCL) <br />TKN 346 2,127 --None <br />Fe ----23 300 mg/L (sMCL) <br />Mn ----16 50 mg/L (sMCL) <br />Notes: <br />1.Effluent concentrations from the rinsate is an average of samples taken from <br />2018 to 2023 for comparative purposes. <br />2.Effluent concentrations from the residuals is an average of samples taken <br />from 2018 to 2023 for comparative purposes. <br />3.Averages of constituents from downgradient wells AMW-44, AMW-45, and <br />AMW-46 were taken from 2020 to 2023. Averages of constituents from <br />downgradient well AMW-14 were taken from 2018 to 2023. <br />a.Salinity. For the purposes of evaluation, TDS is representative of overall <br />salinity. The best measure of total salinity in groundwater is TDS. The <br />concentration levels of TDS in the effluent, both in the rinsate and <br />residual, are high. The overall concentration trend for TDS in the effluent <br />is increasing based on data from 2014 to 2021. However, since the <br />implementation of the 2017 Nutrient Management Plan, the concentration <br />trend for TDS in effluent has been decreasing over time. It should be <br />noted that the downgradient groundwater concentrations of TDS are <br />stable in groundwater wells AMW-44, AMW-45, AMW-46, and AMW-14. <br />While the TDS concentration limits consistently exceed the 500 mg/L <br />sMCL in AMW-44, AMW-45, and AMW-46, the concentrations are below <br />the upper sMCL of 1,000 mg/L. AMW-14, being the furthest downgradient <br />groundwater well, shows that TDS concentration levels have be trending <br />down since 2018 and is currently under the 500 sMCL. Discharges of <br />rinsate and residual cannery waste with respect to TDS do not appear to <br />be degrading groundwater beyond existing conditions at this time and will <br />not unreasonably affect beneficial uses of groundwater. <br />Upon receiving a Notice to Comply with the SCP, the Discharger will be <br />subject to the Basin Plan’s Conditional Prohibition of Salinity Discharges <br />until the Discharger has established participation in the SCP Conservative