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DRAFT [TENTATIVE] WASTE DISCHARGE REQUIREMENTS ORDER R5-2023-00XX 35 <br />FORWARD, INC. <br />FORWARD LANDFILL <br />SAN JOAQUIN COUNTY <br />Approach or the Alternative Approach (i.e., the P&O Study). Compliance <br />with the requirements of the SCP constitutes the BPTC for salinity. Prior to <br />receiving a Notice to Comply with the SCP, the Discharger will be required <br />to comply with the groundwater limits of this Order (see Discharge <br />Specifications B.12, which constitutes the BPTC for salinity. <br />b.Nitrate as Nitrogen. For nutrients such as nitrate, the potential for <br />groundwater degradation depends on wastewater quality and the ability of <br />the vadose zone below the LAAs to support nitrification and denitrification <br />to convert nitrogen to nitrate or nitrogen gas (ammonia) before it reaches <br />the water table. Nitrate levels are significantly high in both the rinsate and <br />residual cannery waste effluent concentrations. For downgradient wells <br />AMW-44, AMW-45, and AMW-46, nitrate concentrations are generally <br />around the primary MCL of 10mg/L. It is difficult to determine if these <br />higher nitrate concentrations are the result of the LAA since nitrate levels <br />upgradient to the entire facility show nitrate concentration values <br />consistently above 10 mg/L. For nitrate concentrations in AMW-14 from <br />2018 to 2023, the concentrations are decreasing. Discharges of rinsate <br />and residual cannery waste with respect to nitrate do not appear to be <br />degrading groundwater beyond existing conditions at this time and will not <br />unreasonably affect beneficial uses of groundwater. <br />TKN concentrations in effluent are within the same concentration range of <br />nitrate as nitrogen. The concentration trend of TKN in effluent is <br />decreasing over time in both rinsate and residual. TKN data has not been <br />collected from the downgradient groundwater monitoring wells. This Order <br />requires that TKN be analyzed in AMW-44, AMW-45, AMW-46, and AMW- <br />14 in order to establish a trend in TKN concentration in the downgradient. <br />This Order also requires continued monitoring for nitrate in the effluent <br />and groundwater, as well as continued BPTC implementation. <br />c.Iron and manganese. Fe and Mn can be present in groundwater as a <br />result of excessive BOD loading rates, which can deplete oxygen, <br />resulting in anoxic conditions. An anoxic environment can solubilize <br />naturally occurring metals in the soil, including Fe and Mn. <br />Fe and Mn data concentrations have not been collected in the effluent. <br />This Order requires that Fe and Mn to be monitored in the effluent and <br />groundwater, as well as continued BPTC implementation. <br />115.These WDRs require the Discharger to provide treatment and control of the <br />discharge that incorporates the following measures: <br />a.Cannery waste shall be incorporated within 24 hours of receipt,