ARCHIVED REPORTS_RPT OF WASTE DISCHARGE FOR WASTEWATER DISPERSAL 2011

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REPORT OF WASTE DISCHARGE- APPENDIX D Diamond Pet Food Processors of Ripon,LLC June 30,2011 Report of Waste Discharge—Antidegradation Analysis Page 13 of 14 NO PROJECT ALTERNATIVE With a No Project Alternative, there would not be any additional or new costs. The Diamond Plant would not operate,but the cogen would continue to operate. There would be no additional or new economic or public benefit, for example, through generation of additional taxes or additional payroll for personnel to operate the Diamond facilities. While the cogen was operating as a water-cooled facility, groundwater quality would remain similar to current conditions, assuming no additional or new development in the area. Once the cogen ceased operation as a water-cooled facility, there would be no discharge at the Diamond site, as it is assumed that the cogen would not continue to produce distilled water in the absence of a buyer(e.g., Diamond). In this event, groundwater degradation would continue to encroach from the wastewater treatment plant ponds to the west and the eucalyptus grove would continue to concentrate salts in the northeastern part of the site. Absent irrigation with higher quality water, groundwater quality as measured by concentration would degrade beneath the site. OPERATION WITH LINED PONDS Typically, a lined pond for storage or retention is considered the Best Practicable Treatment and Control (BPTC) for wastewater or process-water discharges. In a lined pond, the wastewater evaporates rather than percolates. Lined ponds are not considered feasible in this case because of the volume of discharge and the cost—lining the irrigation areas would be prohibitively expensive (likely in the range of$4 to 5 million dollars). Additionally, lining the irrigation areas would have the same effect as no project—the groundwater quality beneath the site (as measured by concentration)would become more degraded, as clean rainwater would be precluded from percolating into the subsurface. PROPOSED PROJECT With the Proposed Project Alternative, there would not be additional costs for developing new storage or retention facilities. The wastewater system would continue to be operated as it has been. There would be new economic benefit, through generation of additional taxes paid on increased income to the facility and additional payroll for personnel to operate the expanded facilities. Although the Proposed Project would affect groundwater quality, the effects are less than those from previous site operations. Discharge of wastewater from the plant after the cogen ceases operation as 010070.00, Task I Lawrence&Associates w:I clients)diamond pet foods1010107.00-ripon rowdldiamondpet_rowdjune2011_draft.docx