SITE INFORMATION AND CORRESPONDENCE

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INFORMATION SHEET • • 2 MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT FACILITY SAN JOAQUIN COUNTY Staff anticipates the proposed expansion of processing capacity will result in the generation of additional high strength wastewater. The Discharger has already increased wastewater flow above the limitations in WDRs Order No. 97-037 and is proposing even higher flows than the interim flow limit in the Revised Time Schedule Order No. R5-2002-0014-ROI. Staff evaluated the water balance in the RWD, and found that the proposed flow of 1,000,000 gallons per day(as a yearly average) can not be contained under a 100 year annual precipitation event. Therefore, this Order contains a flow limitation of 700,000 gpd as a monthly average. A natural surface water drainage exists in the land application areas. During the summer of 2002, the Discharger constructed tailwater collection ditches to prevent tailwater from draining into the surface water drainage. Collected tailwater will be pumped to the new 114-million gallon storage pond or the 1-million gallon storage pond. The Discharger has proposed allowing uncontaminated stormwater to bypass the storage pond. However, until the Discharger can present bypass criteria that is approved by the Executive Officer, all tailwater/ stormwater draining from the land application areas shall be collected and stored in the 114-million gallon storage pond. 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 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 hasbeen 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