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Steve Gikas and Lori Gikas -2- 19 August 2013 Golden Gate Nut Company/California Nuggets, Inc. 1. The discharge has caused pollution (i.e., exceedance of water quality objectives) for nitrate precursors, total dissolved solids, iron, manganese, and chloride. The Central Valley Water Board cannot allow this pollution to continue or get worse. 2. The likely cause of the pollution is over application of high strength wastewater to the 5.2- acre land application area (LAA). Over application of wastewater has the following effects. • Nitrogen overloading. which causes excess nitrate and nitrate precursors to accumulate in the soil; • Prolonged saturation with high biochemical oxygen demand (BOD) wastewater, which causes iron and manganese in the soil to dissolve; and • Forced percolation of the excess nitrogen, salts, dissolved organic matter. and metals to shallow groundwater. Planned Improvements Golden Gate Nut Company must remedy the causes of pollution as soon as practical. The RWD states that the following improvements will be implemented: 1. Segregation of oil recycling wastewater for off-site disposal to reduce BOD and salts, 2. Installation of a treatment system to remove BOD and nitrogen, 3. Planting alfalfa in the LAA to maximize nutrient and water uptake, 4. Installation of sprinkler nozzles that will enhance evaporation, 5. Planting trees around the LAA perimeter to improve water uptake, and 6. Lining the existing storm water pond for use as additional wastewater storage The RWD does not specify when these measures will be implemented. Because the discharge has caused pollution, the WDRs must include a specific time schedule for completion of all work required to bring the discharge into compliance with the Basin Plan. Additionally, the RWD does not contain information showing that proposed improvements will be sufficient to stop the causes of pollution. Specifically, the information presented in the RWD Addendum indicates that the total land application area should be at least 12 acres planted with alfalfa to ensure nitrogen and water loading at rates consistent with crop needs However, this estimate does not consider protective loading rates for BOD and salts, and it is likely that more than 12 acres would be required to stop the cause of pollution and restore shallow groundwater quality to concentrations that do not exceed the water quality objectives Request for Additional Information Water Code section 13267 states, in relevant part: ... the regional board may require that any person who has discharged, discharges, or is suspected of having discharged or discharging, or who proposes to discharge waste within its region . .shall furnish, under penalty of perjury, technical or monitoring program reports which the regional board requires. The burden, including costs, of these reports shall bear a reasonable relationship to the need for the report and the benefits to be obtained from the reports. In requiring those reports, the regional board shall provide the person with a written explanation with regard to the need for the reports, and shall identify the evidence that supports requiring that person to provide the reports.