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REGIONAL WATER BOARD REMPNSE (SWRCB/OCC FILE A-1886) • -10- PETITION FOR REVIEW OF WAZfE DISCHARGE REQUIREMENTS ORDER NO. R5-2007-0113 (NPDES NO. CA0079243) CITY OF LODI, WHITE SLOUGH WATER POLLUTION CONTROL FACILITY CONTENTION J: PERMIT DOES NOT COMPLY WITH CCR TITLE 27 The Permit allows for land disposal of sludge, untreated industrial wastes and domestic wastewater that fails to comply with CCR Title 27. The discharges of domestic sewage or treated effluent are exempt from Title 27 under section 20090(a).' Residual sludges or solid waste are not exempt. The biosolids supernatant and DAF subnatant are liquids, which are currently discharged to the Storage Ponds, are not defined as residual sludges or solid waste. These wastes are part of the domestic wastewater and fall under the exemption in section 20090(a). Sludge is defined in Title 27, section 20164 as follows, ""Sludge"(SWRCB) means residual solids and semi-solids from the treatment of water, wastewater, and other liquids. It does not include liquid effluent discharged from such treatment processes." Although these discharges are exempt from Title 27, to reduce nitrate loadings to the Storage Ponds, the Discharger is currently implementing a project to route the biosolids supernatant and DAF subnatant to the Facility's headworks. The biosolids that are applied to the agricultural fields are regulated by waste discharge requirements and are required to be applied at agronomic rates, are prohibited from creating a nuisance as defined in CWC Section 13050(m), and must be applied such that the Discharger complies with the groundwater limitations. Therefore, Title 27 does not apply. The petitioner contends that the application of biosolids is not BPTC and the Order should require the biosolids to be hauled to a landfill. The Order requires the Discharger to develop a BPTC evaluation if groundwater monitoring results show that the discharge of waste is threatening to cause or has caused groundwater to contain waste constituents in concentrations statistically greater than background water quality. The petitioner contends that the industrial wastewater discharged to the Storage Ponds and agricultural fields is "designated waste" and is not exempt from Title 27. The industrial wastewater collection system accepts primarily food processing wastewater from Pacific Coast Producers (PCP), a large fruit canning facility. The cannery wastewater contains a high BOD loading that is required to be applied to the agricultural fields at agronomic rates. PCP comprises approximately 90% of the industrial waste flow during the summer months. The remaining industries that discharge to the industrial line include Holz Rubber Company, Valley Industries, M&R Packing, Lodi Iron Works, Chevron, and Van Ruiten Winery. Wastewater from the industrial line does not receive treatment at the Facility. It is either discharged directly to the irrigation fields during the irrigation season or stored in ponds at the Facility during the non-irrigation season. Due to concerns about the industrial dischargers (predominantly the metal finishers), the previous order required the Discharger to evaluate the discharges from The Title 27 exemption for sewage has two parts. It exempts treatment or storage facilities associated with municipal wastewater treatment plants, provided that residual sludges or solid waste is discharge according to the SWRCB-promulgated provisions of Title 27. In addition, it exempts other discharges of domestic sewage or treated effluent that are regulated by WDRs or a waiver, and that are consistent with applicable water quality objectives. The petitioner's cites to section 20090(a) collapses the two types of exemptions. (See, e.g., the discussion of findings at the top of page 16 of the petition.) Since the discharges in question are consistent with applicable objectives and are regulated by WDRs, this distinction is irrelevant except to the extent the discharger suggests this provision required additional findings.