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Bert E. Van Voris - 5 - 17 September 2004 Supervising Engineer The Form 200 submitted under either alternative should identify in Section II the type of discharge as "Wastewater Reclamation" and check in Section IV only the box labeled "New Discharge or Facility." The Form 200 submitted by each entity for the second alternative should identify in Section I the entity's legal status (i.e., Corporation for Jepsen Webb Ranch and Individual for Elven and Shirley Adams) and list in Section III only those parcels owned by the entity. The RWRs for corporate entities submitted under the second altemative should indicate the entity's state of incorporation. As discussed above,the project's recycling component may not require the Regional Board to approve a CEQA document. Compliance with CEQA may be met through the issuance of various permits required for project operation (e.g., San Joaquin County grading permits,NPDES Construction Storm Water Permit, San Joaquin Valley Air Pollution Control Board equipment air emission permit(s)), and consistency with adopted General Plans of the project's land use (i.e., irrigated agriculture). The RWR should specify the current zoning of the parcels proposed for recycled water application as identified by the applicable General Plan (or Specific Area Plan, as appropriate). If it is determined that the offsite discharge requires a CEQA evaluation, the staff resources necessary to prepare this document will delay staff's completion of work plan commitments, many of which pertain to necessary enforcement actions. Accordingly, Musco should retain a qualified professional to perform a CEQA evaluation of its proposed recycling project and submit to Regional Board staff an electronic file (i.e., in MS-WordTm) of an essentially complete draft mitigated negative declaration. This document should(a) evaluate the project's potential to impact the environment in accordance with CEQA and CEQA guidelines, (b) describe effective mitigation measures to decrease any identified impacts to less than significant, and (c) propose a monitoring program to assess the effectiveness of implemented mitigation measures. Once this draft CEQA document is determined to be essentially complete, Regional Board staff will finalize the document and process it along with the project's tentative WDRs/Master Recycling Permit. General Treatment and Disposal Concept. The RWD proposes to treat all of the facility's industrial wastewater, including that currently discharged to the SI, to a level the RWD indicates is suitable for direct use as agricultural supply. Specifically, Musco proposes to segregate and separately treat up to 240,000 gallons per day (gpd) of the facility's high salinity wastestreams(i.e., inorganic dissolved solids (IDS) exceeding 6,000 mg/L) via aerobic biological degradation, ultrafiltration (UF), and multi- stage reverse osmosis (RO). Treatment via RO will generate low salinity permeate and high salinity brine. Because the brine discharge to the SI cannot exceed its 30,000-gpd capacity,the target salt removal for RO treatment will be almost 88 percent, which will require a two-stage RO treatment (i.e., the brine from the first-stage RO unit will be treated by a second-stage RO unit designed for seawater applications). Musco is conducting a pilot study using the proposed treatment train, and projects it will require several months to compile sufficient data to evaluate its feasibility. The quality of RO permeate is characterized as follows: less than 10 mg/L biochemical oxygen demand (BOD) and about 830 mg/L IDS, which will include bicarbonate (471 mg/L), sodium (240 mg/L), and chloride (106 mg/Q. Musco proposes to discharge RO permeate to the reservoir, along with