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r STAFF REPORT,Item 15 CEASE AND DESIST ORDER AND CWC 13308 ORDER MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY SAN JOAQUIN COUNTY opportunity to discuss the ACLC with the Executive Officer or request the matter to be heard by the Board. The proposed C&D Order has a number of requirements, each of which are described below. The Discharger must modify its facility or limit production such that it meets the 500,000 gpd flow limit, the BOD loading limit, and the DIS loading limit contained in the WDRs. For each item, each day of violation after 10 February 2002 will result in a penalty of$2,500 per day. This requirement is necessary to bring the Discharger into compliance with its WDRs, and may result in the Discharger reducing production, addressing source control measures, and/or constructing additional Title 27 impoundments. Staff realize that this is an economic burden,but the Discharger has been on notice since May 2000 that it needs substantial improvements or operational changes to comply with its WDRs, yet the Discharger has not made the improvements and has continued to aggressively expand its processing capability. Staff also directed the Discharger in the May 2000 Water Code Section 13267 letter to review alternatives for source control procedures at the facility. It is unknown whether the Discharger has pursued this option. The proposed C&D Order requires Musco to submit a groundwater monitoring well installation workplan and three months later, a groundwater monitoring well report of results. This requirement is a result of the limited hydrogeologic study that was completed as part of the C&A. The study showed that that groundwater depths are shallower than previously known and that the aquifer material is thicker than previously expected. Therefore, Musco needs to show whether or not the application of saline wastewater to land is impacting the underlying groundwater. The C&D states that there will be a S2,500 penalty for each day in which these two reports are late or incomplete. The proposed C&D Order also requires that Musco evaluate its domestic wastewater system, which consists of septic tanks, leachlines, and seepage pits. The Discharger stated during the 2 November 2001 inspection that approximately 350 employees work at the facility, yet the San Joaquin County Environmental Health Department's October 2001 records show that the system is designed for only 164 employees. In addition, the Discharger has recently begun spraying its industrial wastewater to land directly over the leachlines and seepage pits. Therefore,the domestic system needs to be evaluated for two reasons: whether it can adequately treat the flows it receives, and whether the application of industrial wastewater is compromising the ability to treat and dispose of domestic waste. The C&D states that there will be a$2,500 penalty for each day in which this report is late or incomplete. Musco will also be required to submit monthly status reports describing all work completed in response to the C&D Order. These reports shall also contain daily tabulations of flow rates, BOD loading rates, and DIS loading rates. There will be a $2,500 penalty for each day a report is incomplete or late. Finally, the Discharger must submit a report by 1 July 2002, showing how it has modified its facility so that it is in full compliance with WDRs No. 97-037 and C&A Order No. 5-00-717. If full compliance is not achieved by this date, then within ten days of written notification by the Executive Officer, the Discharger must immediately cease the discharge of all wastewater, including the land application areas and the Class 11 ponds. The 1 July 2002 compliance date gives the Discharger an extra eight months to