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INFORMATION SHEET • • - 14 - MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY SAN JOAQUIN COUNTY Discharger has requested permission to apply wastewater during rain events. Staff is concerned that due to low permeability rates, applied wastewater will run off the land application areas and could be diverted around the 84-million gallon storage pond. Until the watershed evaluation is completed, specific criteria on diversion is presented to the Regional Board, and the Executive Officer approves the criteria, all diversions are prohibited. Discharge Prohibition A.11 The Discharger has asked that this restriction prohibiting grazing animals at the land application area be changed to state "Grazing of animals on the sprayfields must be followed by discing or ripping of the soil prior to resumption of process water application." The requested change was not made for several reasons. First, the Discharger has indicated during staff inspections that grazing cows have damaged sprinkler heads, leading to discharges to the surface water drainage course. It is staff's understanding that the cows have recently been removed from the sprayfield. In addition, the RWD does not explicitly state that the Discharger proposes to allow grazing to continue. Instead, the RWD describes a number of problems with grazing animals on the sprayfields, including increased runoff and soil compaction. The RV,D states "It may be prudent to phase out grazing on the sprayfields." Finally, the Discharger needs to use its entire 200 acres of land in order to meet the BOD and nitrogen loading rates. The Discharger has not shown Trow it will be able to rotate grazing animals with wastewater applications and still meet the requirements of this Order. Discharge Prohibition A.12 This prohibition prohibits industrial wastewater from being applied above the septic system leach lines or seepage pits. Application of wastewater over a leach line/seepage pit can result in wastewater infiltrating the leach lines and traveling to the seepage pits where it can be transported vertically to lower zones with little or no treatment. Discharge Specification B.I The monthly average flow limitation of 800,000 gpd applies to wastewater flowing from the facility into the 1-million gallon storage pond. Because the stormwater which falls onto the facility is commingled with wastewater and is also pumped into the 1-million gallon storage pond, the flow limitation includes this stormwater. In a wet winter,the Discharger may need to reduce its processing activities to meet the flow limit. The flow limit is based on staffs understanding that all wastewater enters the 1-million gallon storage pond before it is pumped to either land or the 84-million gallon pond. If the Discharger changes its piping system (i.e., so that some wastewater is pumped directly to the 84-million gallon pond),then it will need to install new flow meters to meet compliance with the limitation. The flow limitation does not apply to wastewater, which is pumped onto the land application area. The Discharger is free to apply as much wastewater as necessary to the land application areas, as long as it complies with all other aspects of this Order. The flow limitation also does not apply to tailwater returned to the 84-million gallon pond, or to stormwater from the land application area which is directed to the 84-million gallon pond. Discharge Specification B.3 This specification limits discharge of wastewater or other waste constituent to storage ponds, storage areas, or land application areas at concentrations that can cause a violation of the Groundwater Limitations. The Groundwater Limitations states the discharge shall not cause underlying groundwater to contain waste constituents in concentrations statistically greater'then background water quality.