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D R A F T January a, 2012 pollutants, that could be present in the wastewater. The Central Valley Water Board has addressed this issue by requiring the City to submit an industrial influent characterization study. c. Wastewater Characterization Additionally, CALSPA contends that it is not appropriate to exempt the secondary treated wastewater from Title 27 because this waste stream has not been adequately characterized. CALSPA asserts that secondary effluent can be expected to have more contaminants and at higher concentrations than tertiary-treated effluent. CALPSA's concern about wastewater characterization has merit. The secondary waste stream is stored in the onsite ponds and applied to the agricultural fields at the Facility. As explained previously, there is very little monitoring information on the wastewater in the ponds, other than for nitrogen and salts. Order No. R5-2007-0113 contains only two effluent limitations, for BOD and suspended solids, that apply to the discharge of secondary effluent to the onsite ponds. The Central Valley Water Board has recognized the need to better characterize wastewater in the ponds and has required additional pond monitoring. To the extent that secondary effluent is mixed with industrial wastewater and the biosolids slurry and applied to the agricultural fields, the conclusions on the wastewater mixture discussed above apply here as well. 5. Action on Remand The Board has concluded that the monitoring performed to date at the White Slough Facility is inadequate to show that the City's land disposal activities comply with preconditions for an exemption from Title 27. In addition, evidence in the record indicates that the releases of wastewater from the onsite storage ponds have caused the underlying groundwater to exceed the applicable Basin Plan nitrate and EC objectives. Therefore, the findings in Order No. R5-2007-0113 must be revised, on remand, to reflect that the City's land disposal activities do not currently meet the criteria for an exemption. Until the City provides sufficient evidence to the Central Valley Water Board that it meets the preconditions for an exemption and the board finds that the City qualifies for the exemption, the Central Valley Water Board can regulate the City's land disposal activities under an appropriate enforcement order, such as a time schedule order, or under an appropriate time schedule included in Order No. R5-2007-0113.4' To demonstrate compliance with the exemptions from Title 27, the City must develop an appropriate monitoring program that adequately characterizes groundwater quality 47 See Wat. Code, §§ 13263, subd. (c), 13300. 19.