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WASTE DISCHARGE REQUIREMENTS ORDER NO.R5-2002-0148 - 16- MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY SAN JOAQUIN COUNTY c. The wastewater is nonhazardous waste and need not be managed according to Title 22, CCR, Division 4.5, Chapter 11, as a hazardous waste. ANTI-DEGRADATION ANALYSIS 76. State Water Resources Control Board (State Board)Resolution No. 68-16 (hereafter Resolution No. 68-16)requires that waste be discharged in a manner that maintains the high quality waters of the state. Any change in quality can occur only after full application of best practicable treatment and control (BPTC) of the waste, and must be consistent with maximum benefit to the people of the State, not unreasonably affect a beneficial use, and not result in water that exceeds a water quality objective. Where the water quality objective is exceeded in background water quality but nonetheless beneficially used or designated for beneficial use, the background water quality cannot be degraded. 77. Antidegradation factors have been considered pursuant to Resolution No. 68-16. The project as proposed does not threaten to degrade groundwater with nitrogen, assuming that the proposed intensive cropping can be maintained. The project as proposed may degrade or cause degradation of groundwater and possibly create nuisance from organics while waste is ponded and in the manner applied to land. As described in Finding No. 26, the project as proposed will certainly cause pollution with constituents of salt. Degradation of the groundwater with organics and salt is not consistent with maximum benefit to the people of the State. If it were, the Discharger would have to demonstrate its treatment as being best practicable treatment and control (BPTC). The Discharger has made no BPTC demonstration. In short, the project as proposed by the Discharger is not consistent with Resolution 68-16. 78. In considering potential salt degradation of groundwater from the discharge, the salt already within the LTU and underlying soil profile must be considered, and elevated salt is already within the LTU and likely in the soil profile below it given past practices of the Discharger. Given the unacceptability of the salt proposed for discharge, it is not necessary to quantify this factor. 79. Following adoption of WDRs Order No. 97- 037, the Discharger has been provided ample opportunity to justify a discharge and comply with Order No. 97-037. It has not complied. It has been granted interim conditional flow increases while under a series of enforcement actions while developing justification for discharge, and violated those conditions including repeated failure g g p e to monitor waste and submit reports as required, and failure to restrain production in accord with enforcement conditions, resulting in administrative civil liability. The RWD is inadequate to support the requested discharge. Therefore, this Order limits the Discharger to that which will not degrade the underlying groundwater. GROUNDWATER DISCHARGE ANALYSIS —LAWS, RULES,AND REGULATIONS 80. For the waste constituents present in the discharge in significant concentrations, the water quality objectives determined by the translator process from narrative objectives are all less than observed background water quality, except for nitrate. Because all forms of nitrogen can convert to nitrate