SITE INFORMATION AND CORRESPONDENCE

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ORDER NO.R5-2002-0148 3 INFORMATION SHEET MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY SAN JOAQUIN COUNTY the tentative WDRs prohibit bypass until the Discharger provides acceptable criteria to show that wastewater will not be present in the stormwater. The ability to bypass wastewater is a critical assumption in the water balance and may impact the Discharger's ability to operate. The water balance includes application of wastewater in months when rainfall exceeds evapotranspiration(ET). Such an application is likely to result in considerable generation of tailwater, all of which is required to be collected. For example, March rainfall is 4.1 inches,potential ET is 3.0 inches, yet 5.2 inches of wastewater(approximately 35.3 Mgal) is proposed for application. The water balance's failure to adequately address tailwater generation that might result from such an application is described below. The water balance is optimistic in calculating the tailwater generation rate and is inconsistent when calculating tailwater generation rates and stormwater runoff. The tailwater generation rate is significantly lower than the anticipated stormwater runoff rate used to calculate the amount of stormwater runoff from land application areas. The discrepancy exists despite the soil moisture content at 100-percent. Stormwater runoff is anticipated to be approximately 26-percent of rainfall; tailwater runoff is anticipated to be in the range of 0.06, when it is reported at all. The Discharger reports wastewater will be applied in short frequent applications to minimize stormwater runoff, but that approach requires the Discharger to operate the entire land application area with computer controlled spray equipment, which the Discharger has not installed. It is noted that the water balance predicts at least 5 inches of wastewater application in both March and April,but only 0.3 and 0.0 inches, respectively, of tailwater runoff is predicted. If the tailwater generation rate is higher than predicted, the wastewater storage pond will run out of capacity and in critical months, the lack of capacity will result in spilling of wastewater. The water balance's cumulative storage volume scenario is difficult to imagine. For example, at the end of February(with the storage pond containing 83.6 Mgal of wastewater), the storage pond will only accumulate 0.4 Mgal of additional wastewater despite the unfavorable conditions of rainfall exceeding evapotranspiration, 5.2 inches of applied wastewater, and 100-percent saturated soil. With all those factors to overcome, the water balance estimates 0.3 inches of tailwater runoff. Based on observations during site inspections, staff believes considerably more tailwater will be generated than what is described in the water balance. The water balance addresses the lack of capacity in the wastewater storage pond by establishing higher rates of leaching wastewater when the storage pond nears capacity. For example, the storage pond contains 83.6 Mgal at the end of February; in March the water balance then predicts 5.3 inches of leaching to prevent the pond from overfilling. If the leaching rate is less than expected, the pond will overfill and spill. Additional Restrictions Due to Water Balance Concerns One of the major problems with the water balance is that both tailwater and stormwater generation and storage rates are estimated. At this point, there is no way to verify the estimations except through direct measurements over the next few years. However, staff need to propose a flow limitation at this time.