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WASTE DISCHARGE REQUIREMENTS ORDER NO. • 15- <br /> MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY <br /> WASTEWATER TREATMENT FACILITY <br /> SAN JOAQUIN COUNTY <br /> d. Specific standards be prescribed by which to monitor water quality (§20420), including a <br /> detection monitoring program (§20420), an evaluation monitoring program (§20425), and an <br /> unsaturated zone monitoring program for the LTU (§20435), which requires soil-pore liquid <br /> monitoring to assure effective operation. <br /> 74. Pursuant to §20090(b), the Board may exempt a discharge from Title 27 only if: <br /> a. The Regional Board issues waste discharge requirements; <br /> b. The waste discharge requirements implement the Basin Plan and allow discharge only in <br /> accordance with the Basin Plan; and <br /> c. The wastewater is nonhazardous waste and need not be managed according to Title 22, CCR, <br /> Division 4.5, Chapter 11, as a hazardous waste. <br /> ANTI-DEGRADATION ANALYSIS <br /> 75. State Water Resources Control Board(State Board)Resolution No. 68-16 (hereafter Resolution <br /> No. 68-16) requires that waste be discharged in a manner that maintains the high quality waters of <br /> the state. Any change in quality can occur only after full application of best practicable treatment <br /> and control (BPTC) of the waste, and must be consistent with maximum benefit to the people of <br /> the State, not unreasonably affect a beneficial use, and not result in water that exceeds a water <br /> quality objective. Where the water quality objective is exceeded in background water quality but <br /> nonetheless beneficially used or designated for beneficial use, the background water quality cannot <br /> be degraded. <br /> 76. Antidegradation factors have been considered pursuant to Resolution No. 68-16. The project as <br /> proposed does not threaten to degrade groundwater with nitrogen, assuming that the proposed <br /> intensive cropping can be maintained. The project as proposed may degrade or cause degradation <br /> of groundwater and possibly create nuisance from organics while waste is ponded and in the <br /> manner applied to land. The project as proposed will certainly cause pollution with constituents of <br /> salt. Degradation of the groundwater with organics and salt is not consistent with maximum <br /> benefit to the people of the State. If it were, the Discharger would have to demonstrate its organic <br /> treatment as being best practicable treatment and control (BPTC). The Discharger has made no <br /> BPTC demonstration. In short, the project as proposed by the Discharger is not consistent with <br /> Resolution 68-16. <br /> 77. In considering potential salt degradation of groundwater from the discharge, the salt already within <br /> the LTU and underlying soil profile must be considered, and elevated salt is already within the <br /> LTU and likely in the soil profile below it given past practices of the Discharger. Given the <br /> unacceptability of the salt proposed for discharge, it is not necessary to quantify this factor. <br /> 78. Following adoption of WDRs Order No. 97- 037,the Discharger has been provided ample <br /> opportunity to justify a discharge and comply with Order No. 97-037. It has not complied. It has <br /> been granted interim conditional flow increases while under a series of enforcement actions while <br /> developing justification for discharge, and violated those conditions, including repeated failure to <br /> monitor waste and submit reports as required, and failure to restrain production in accord with <br /> enforcement conditions,resulting in administrative civil liability. The RWD is inadequate to <br />