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c WASTE DISCHARGE REQUIREMENTS ORDER NO,R5-2042-0225 12 ALPINE PACKING COMPANY,INC. WASTEWATER TREATMENT SYSTEM, SAN JOAQUIN COUNTY becomes the governing water quality objective. However, the Discharger is required to further define background groundwater quality. 66. The discharge is nonhazardous,but exhibits characteristics of"designated waste," as the concentrations of some waste constituents when treated, stored, and applied to land have potential for causing exceedances of water quality objectives or adversely affecting beneficial uses. The discharge contains decomposable waste constituents (e.g., organic carbon and nutrient compounds) and inorganic dissolved solids in concentrations that are greater than water quality objectives. 67. The discharge must be categorized as designated waste because of these constituents and subjected to the full containment provisions of Title 27 unless it can be demonstrated that constituents of concern, after release, are effectively and consistently removed by attenuation in the soil profile and the discharge fully compliant with the Basin Plan. For waste applied to the land treatment unit, it means a demonstration that controlled land treatment removes waste decomposable constituents within the LTU and, for those not totally decomposable, passes through concentrations that will cause no degradation of groundwater. 68. The waste that is discharged to land contains TDS (and presumably sodium and chloride)well in excess of governing background quality and these constituents are not effectively removed by the LTU. The practical demonstration of removal of dissolved solids as projected by the Discharger has not been demonstrated as required for an LTU. The Discharger has not established the design LTU depth that is dependent upon crop. The Discharger has not established an evaluation monitoring program,unsaturated zone monitoring program, or water quality protection standards for each waste constituent. Inorganic dissolved solids can be effectively controlled by means of source control, treatment, or containment. Source control includes best management practices of selective and judicious chemical use (e.g.,potassium-based cleaning solutions instead of sodium- based) and waste stream isolation or segregation where possible (in particular separate handling of high strength wastewater, ion exchange regeneration brine, boiler blowdown, and cleaning chemicals). Treatment technology includes reverse osmosis and ion exchange applied to the wastewater, but we have no evidence that any have been evaluated or applied to the discharge. Containment technology includes Title 27 prescriptive standards where appropriate,but there is no evidence that these were considered for implementation for all applicable waste streams. 69. In regards to decomposable waste, the Discharger has not, among other things, demonstrated the appropriate loading of the LTU. However, as a general guide,Pollution Abatement recommends an LTU for food-processing wastewater not exceed a loading of BODS of 100 lbs/acre-day to prevent development of nuisance odor conditions. The RWD did not present the loading rate due to incomplete data. Staff's evaluation of available data indicates the discharge is well below the guidance described above. OTHER REGULATORY CONSIDERATIONS 70. CWC § 13267(b)provides that: "In conducting an investigation specified in subdivision (a), 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, or any citizen or domiciliary, or political agency or entity of this state who has discharged, discharges, or,