SITE INFORMATION AND CORRESPONDENCE

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Bert E. Van Voris -4 - 17 September 2004 Supervising Engineer Form 200) California as the state in which Musco is incorporated and Studley Company is registered as a partnership. Section II should also check"Land Treatment Unit," "Surface Impoundment," "Industrial Process Wastewater," and"Storm Water." Section IV should also check "Change in Quantity/Type of Discharge." In Section V, the "CEQA finding"in Order No. R5-2002-0148 is 93, not 95. While the Regional Board's case file for Musco should contain the CEQA document for the current discharge, the RWD should include a copy of the Negative Declaration approved by the San Joaquin County Community Development Department for the reservoir. It may be necessary to conduct another CEQA evaluation for the proposed project as it may cause impacts not considered in the original CEQA evaluation. For example,the construction and operation of the proposed industrial wastewater treatment plant may adversely impact air quality unless mitigation measures are implemented to reduce these impacts to less than significant. Consultation with Regional Board counsel and appropriate responsible agencies (e.g., San Joaquin Valley Air Pollution Control District, San Joaquin County) is necessary to evaluate whether the Regional Board can determine the proposed project—including its offsite recycling component—exempt from CEQA. Form 200 -RWR Section I,Facility Information, identifies the facility owner and operator as Musco and owners of the land as Jepsen Webb Ranch, LLC (Corporation), and Elven and Shirley Adams (Individual Owners). Section II, Type of Discharge, identifies the discharge as "Other" and defines it as "Irrigation with reclaimed wastewater." Section III, Location of Facility, lists the APN for the facility as 209-11-31, one of two parcels listed for facility location in Section III in the RWD's Form 200. Section III identifies three parcels comprising the proposed wastewater recycling areas. The technical report accompanying the RWR identifies the ownership of these parcels. Section IV, Reason for Filing, identifies the reason as "Other" and defines it as "Change in location of discharge." Section V, CEQA, identifies the Regional Board as the lead agency, indicates (a) a public agency has determined the project is not exempt from CEQA, (b) that a Notice of Determination has not been filed under CEQA, and (c)the expected CEQA document is a Mitigated Declaration. Section VII, Other, states, "Reclaimed Facility Wastewater will be used for agricultural irrigation at two properties including Jepsen Webb Ranch and Valley Thoroughbred Farm, which are located East of the Facility [emphasis added]." Comment: While it is clear that Musco is requesting the Regional Board adopt water reclamation requirements for its proposed recycling project, Musco's certification of the RWR's Form 200 implies it seeks master reclamation permit which, pursuant to CWC Section 13523.1(b)(1),is issued along with WDRs. Under this permitting alternative, potential users of Musco's recycled wastewater would apply for permission directly to Musco, which would regulate the user's recycling operation. This alternative would streamline the process of approving wastewater recycling by entities not yet identified by Musco in the RWR. In lieu of a Master Reclamation Permit/WDRs, users of Musco's recycled water may be issued individual water recycling requirements (WRRs). Under this alternative, each entity proposing to recycle Musco's wastewater must submit a complete Form 200 and RWR at least 140 days prior to initiating wastewater recycling.