SITE INFORMATION AND CORRESPONDENCE

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WASTE DISCHARGE REQUIREMENTS ORDER NO. - 17- MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY SAN JOAQUIN COUNTY Where background water quality is unaffected by other discharges and greater than water quality objectives, the background water quality governs. 81. The general concentrations of key waste constituents in the effluent, storage pond, and in wastewater applied to land compare with groundwater and water quality objectives as follows: 1-million On-Site ag llon Supply Well Background settling pond (Average) Groundwater' Objectives DIS 2,718 NM' NM NA' Chloride 415 334 601 106 Sodium 739 372 597 103 TDS 4,737 1,513 2,047 450 Total Nitrogen 61' 4.4 6° 10 BOD 3,040 NM NM 0 NM denotes Not Measured : NA denotes Not Applicable ' All nitrogen was present as TKN,nitrate no detected in the samples. ° Reported as the average sum of NO3 as N and total Kjeldahl nitrogen. Background quality defined by the average concentrations plus two standard deviations of samples from the onsite supply well. 82. The discharge is nonhazardous,but exhibits characteristics of"designated waste," as the concentrations of some waste constituents when treated, stored, and applied to land have potential for causing exceedances of water quality objectives or adversely affecting beneficial uses. The discharge contains decomposable waste constituents (e.g., organic carbon and nutrient compounds) and inorganic dissolved solids in concentrations that are greater than water quality objectives when released from any of these structures or from what is applied to land. 83. The discharge must be categorized as designated waste because of these constituents and subjected to the full containment provisions of Title 27 unless it can be demonstrated that constituents of concern, after release, are effectively and consistently removed by attenuation in the soil profile and the discharge fully compliant with the Basin Plan. For constituents that may infiltrate from inverts of ponds, this means a demonstration of the effectiveness of liners in containing the constituent, a scientific demonstration of attenuation within the soil profile beneath lined and unlined ponds for released waste constituents, and technical evidence that groundwater will not be degraded by the constituents. For waste applied to the land application area, it means a demonstration that controlled land treatment removes waste decomposable constituents within the LTU and, for those not totally decomposable, passes through concentrations that will cause no degradation of groundwater. Given the applicability of Title 27, some of its definitions and terms are used herein. 84. The waste that is discharged to ponds and land contains TDS and sodium well in excess of governing background quality and is not effectively removed by the LTU. The discharger has made no demonstration that the LTU can achieve salt removal by land treatment,but proposes use of crops for this purpose and has provided theoretical projections of crop uptake of salt. TDS can C:.W I.%M%W M,,kq'W U W R6&.