SITE INFORMATION AND CORRESPONDENCE

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INFORMATION SHEET • • - 4 - MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY SAN JOAQUIN COUNTY and then bypassing the wastewater/stormwater mix may result in discharge of wastewater off site, a situation that is expressly prohibited by the WDRs. Therefore, it is reasonable to include a prohibition against applying wastewater during the three months (December-February)when stormwater bypass is proposed and when the water balance indicates that wastewater will not be applied to land. Because of the uncertainties of tailwater generation and the importance to preparation of any future water balances, it is reasonable to require monitoring of the amount of tailwater generated. The Discharger has verbally described a plan (but has yet submitted a written description) to collect tailwater from the application areas in collection ditches and return the water to the storage pond in a sump/pump/piping arrangement. Monitoring of the tailwater will allow a better evaluation of the flow rate for future preparation of water balances. The monitoring might consist of totalizing meters or pump run time meters. If pump run time meters are used, annual calibration of the meters should be required because the Discharger has reported inaccurate metered flow rates in the wastewater discharge self-monitoring data. The Discharger also needs to either directly measure, or accurately estimate, the amount of stormwater which rums off the land application area and is collected in the storage pond. Finally, because the water balance contains optimistic assumptions, it is reasonable to include a requirement to cease the discharge to the either the 1-Mgal settling pond or the 84-Mgal storage pond if the freeboard in either is less than two feet at any time. This will minimize the possibility of spilling wastewater into the natural surface water drainage. The Discharger is also required to inform Regional Board staff of the freeboard violation immediately. REGULATORY CRITERIA Based on the available information regarding groundwater quality, the wastewater contains higher concentration of DIS, sodium, and chloride than the groundwater. It may also contain other analytes in concentrations higher than the underlying groundwater. The discharge is nonhazardous, but exhibits characteristics of"designated waste," as defined by CWC Section 13173(b), as the concentrations of some waste constituents when applied to land have potential for causing exceedances of water quality objectives or affecting beneficial uses. The discharge contains decomposable waste constituents (e.g., organic carbon and nutrient compounds) and inorganic dissolved solids in concentrations orders of magnitude greater than water quality objectives. The Discharger proposes to continue the discharge of wastes to land, and hence the groundwater, that are subject to full containment under Title 27. However, the discharge of such designated waste to land is not allowed under WDRs No. 97-037, and is also not allowed under this updated Order. The updated Order contains an analysis of the RWD for requirements under which an exemption from Title 27 may be granted and, as intended by the RWD, for the conditions under which waste may be discharged to a land treatment unit, followed by infiltration to groundwater. The Regional Board has considered antidegradation pursuant to Resolution No. 68-16 and finds that degradation of the groundwater by this discharge is not consistent with maximum benefit to the people of the State. Under ideal conditions, the assimilative capacity of the underlying soil and proper irrigation management practices should prevent degradation of groundwater from the infiltration of incidental waste