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WASTE DISCHARGE REQUIREMENTS ORDER NO. • I7 MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT FACILITY SAN JOAQUIN COUNTY 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. 83. The waste that is discharged to ponds and land contains TDS, sodium, and chloride 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. Inorganic dissolved solids can be effectively controlled by means of source control, treatment, or containment. Source control includes best management practices of selective and judicious chemical use(e.g.,potassium-based cleaning solutions instead of sodium-based) and waste stream isolation or segregation where possible (in particular separate handling of CIP wastewater, ion exchange rinsate, and boiler blowdown). Such control practices have been employed for these waste streams, but not for cannery floor water or CIP waste. Treatment technology includes reverse osmosis, ultra-filtration, and ion exchange applied to the wastewater, but we have no evidence that any have been evaluated or applied to the discharge. Containment technology includes Title 27 prescriptive standards where appropriate,but there is no evidence that these were considered for implementation for all applicable waste streams. The Discharger has not demonstrated failsafe control technology for diverting alternating waste streams of what has been identified for Title 27 containment ponds and what has not, as brine waste can easily be diverted by personnel into the waste streams regulated by this discharge. Automatic sensing devices linked to continuous monitors are available for this purpose, and segregated piping has not been determined as infeasible. 84. The practical demonstration of removal of salt as projected by the Discharger has not been demonstrated as required for a LTU and, in the judgment of this Board, is excessively optimistic. The Discharger has not established the design LTU depth which is dependent upon crop. The Discharger has not established an evaluation monitoring program, unsaturated zone monitoring program, or the water quality protection standards for each waste salt constituent. It is evident that the proposed chloride and sodium concentrations will adversely affect crop health through foliar absorption and adverse affects on soil and reduce yields, and salt uptake. The Discharger has not scientifically quantified what plant salt will be removed through harvesting or from a practical aspect how severe slopes will be harvested, so it remains unclear how much salt, if any,will actually be removed from the site. Cropping with high quality water requires a leaching fraction to leach salt accumulation from the soil, and as water quality decreases the leaching fraction must increase. Successful cropping will require a large leaching fraction that the Discharger estimates at 10-percent. However,the leaching fraction is always more concentrated than the applied water. Water applied by sprinkler in a hot climate will have an application efficiency of about 70%. If Sudan grass requires 49 inches of water per year for evapotranspiration, with a leaching factor of v,lW_Lq.uJiwlMullM�.TMwvvUP.M.Iz