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INFORMATION SHEET • • - 5 - MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY SAN JOAQUIN COUNTY constituents. 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 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. The RWD proposes that wastewater containing over 3,000 mg/1 TDS be discharged to land, however, staff's analysis shows that an interim effluent limitation of 2,047 mg/1 TDS is necessary to protect the underlying groundwater. Inorganic dissolved solids can be effectively controlled by means of source control and treatment. Source control includes best management practices of selective and judicious chemical use and waste stream isolation where possible (for example, clean-in-place wastewater, ion exchange regeneration brine, lye bath rinse water, and boiler blowdown). Treatment and containment technology includes reverse osmosis, ion exchange, and evaporation impoundments constructed to Title 27 standards LOADING RATES The RWD describes the animal nitrogen loading rate to be between 4281bs/acryear to 490 lbs/ac-year. The Discharger will double crop Sudan grass and also grow winter barley. The Discharger states that it will stagger planting, irrigation, and harvest so that there are always two or three crops in the land application areas. The RWD reports double cropping the Sudan grass will remove approximately 325 pounds of nitrogen per acre-year. Winter barley will be planted into Sudan grass stubble in early fall to remove an additional 160 pounds of nitrogen per acre/year. Other crops the Discharger is considering are Bermuda grass and salt tolerant alfalfa(reportedly under development in agricultural laboratories).Recent inspections have shown that crop health at the facility has been poor in areas where wastewater has been applied for longer times. Poor crop health will result in lower nitrogen uptake rates. Therefore,the Order requires that the Discharger consult with a Certified Crop Advisor or Certified Agronomist on a yearly basis regarding the steps needed to maintain the proposed intensive agriculture and high nitrogen uptake. The RWD describes the annual DIS loading rate to be between 34,000 lbs/ac-year and 40,000 lbs/ac-year. The Discharger anticipates approximately 3,260 lbs/ac-year will be taken up by cropping activities. The RWD states that leaching of DIS from the root zone must be performed to control soil salinity at levels that do not hinder crop growth. Because the DIS loading rate exceeds the crop uptake rate,it is anticipated that leaching of DIS will result in interim soil attenuation of the DIS and eventual groundwater degradation with continued application. This application procedure is not sustainable with nondegradable constituents. Loading rates must be balanced with uptake rates to protect groundwater quality, and therefore the 1,500 mg/1 effluent limit for TDS is necessary. The Discharger is required to continue characterizing groundwater quality and to begin characterizing the quality of the percolate below the land treatment units. Percolate samples will be collected by pan lysimeters both in areas of land application and areas outside the land application limits. Groundwater monitoring wells will monitor the first saturated interval;percolate samples will be monitored by pan lysimeters installed at a depth of five feet. If groundwater or percolate quality is degraded,the Discharger must take steps such as reducing loading or improving cropping to protect groundwater quality.