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a , CEASE AND DESIST ORDER NO. '3 " AND CWC SECTION 13308 ORDER MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY SAN JOAQUIN COUNTY system. Examples of designated wastes that are discharged to land include cannery floor wastewater(which is high in TDS), spills from the process water tanks where olives are cured in a strong lye e solution, spillage and ills a from storage tanks which contain acetic acid. It is einem expected that further scrutiny will reveal other sources of designated waste being.,discharged to the land application system. e. WDRs Prohibition AA prohibits discharge of wastewater to ponded water. The Discharger has regularly discharged wastewater to drainage courses and to irrigation checks that contain ponded water. f. WDRs Prohibition A.5 prohibits the use of a natural drainage to transmit wastewater. Discharge of wastewater within 100 feet of surface waters is also prohibited. The Discharger routinely discharges wastewater to natural drainage courses. The one million gallon storage pond overfill pipe discharges directly into a surface water drainage course. g• WDRs Discharge Specification B.1 states that the use or production of wastewater shall not cause a pollution or nuisance as defined by the California Water Code, Section 13050. The Discharger has created a condition of offensive odors at the facility and the land application areas as a result of over application of wastewater. The Regional Board received odor complaints on 22 October 2001 and 19 November 2001 from residents living in the area. h. WDRs Discharge Specification B.2 states the use of production wastewater shall not cause a degradation of any water supply. Groundwater samples collected as part of the initial groundwater characterization study performed in June 2001 indicated higher concentrations of sodium, chloride, and TDS in the groundwater sample collected from the boring located near the one million gallon storage pond compared to the second boring drilled in the land application area. i. WDRs Discharge Specification BA requires water used for irrigation to be managed to minimize erosion and runoff. The Discharger's application of wastewater has resulted in significant tailwater generation, which has resulted in significant runoff and erosion. j. WDRs Discharge Specification B.5 prohibits water from standing continuously on any border check or irrigation area for more than 12 hours after wastewater application has ceased. Standing water in land application areas and checks was observed during the site inspections performed in May 2000 and November 2001. k. WDRs Discharge Specification B.6 limits the average Dissolved Inorganic Solids (DIS) concentration (1,264 mg/l) and BOD concentration (3,176 mg/1) in the wastewater applied to land. The Discharger regularly exceeds the limits;between January 2000 and September 2001, the average DIS concentration was 2,421 mg/l, and BOD concentrations frequently exceed the limit. 1. WDRs Discharge Specification B.7 requires land application areas to be cropped where wastewater is applied. The Discharger has failed to crop the land application areas except in small areas. The crops have generally not grown well. E m. WDRs Discharge Specification B.7 and Finding No. 17 prohibit application of wastewater during rain events, and states that there will be a three day resting period between applications and precipitation events. The Discharger's self monitoring reports indicate W:(AGENDA\AGENMATLNComestcdkEnforcrt=t\Musco C4DS.doc