California Regional Water Quality Control Board Central Valley Region

30 July 2003

Mr. Ed Hulbert
Colusa Industrial Properties, Inc.
P.O. Box 731
Colusa, CA  95932

DENIAL OF REQUEST FOR APPROVAL OF NEW DISCHARGE, COLUSA INDUSTRIAL PROPERTIES, COLUSA COUNTY

Regional Board staff has reviewed your technical submittal, which we received on 22 July 2003.  We understand that Colusa Mushroom, a new tenant, wishes to discharge wastewater to the existing Colusa Industrial Properties (CIP) land disposal system.  The discharge of industrial and domestic wastewater generated at the CIP facility is regulated under Waste Discharge Requirements (WDRs) Order No. 5-01-250.  Provision 6 of the WDRs states that discharges from additional processors may be allowed if the Executive Officer approves a technical report that provides specific details of the proposed discharge.  We understand that your report was intended to provide the required information to gain that approval.

Proposed New Discharge
According to the report, Colusa Mushroom originally intended to operate a closed loop system that would generate no wastewater.  However, Colusa Mushroom began composting wheat straw and chicken waste several months ago to make the substrate for mushroom cultivation.  We understand that Colusa Mushroom is not currently growing mushrooms, but is making substrate to sell to other mushroom growers and provide stock for its own future operation.  We also understand that the composting operation, which was permitted by the Colusa County Environmental Health Department, is generating leachate.  The leachate, some of which was generated during a period when the compost piles were anaerobic, has apparently been collecting in a concrete wastewater sump for several months and its presence has caused nuisance odors at the facility.  We understand that Colusa Mushroom now deems it infeasible to operate a closed loop composting system and wishes to discharge approximately 5,000 gallons per day (gpd) of leachate to CIP's designated disposal areas.

There are two key issues associated with the proposed discharge, and these issues must be resolved before there can be any discharge from Colusa Mushroom.  First, neither the 1999 Initial Study nor the current WDRs envision composting.  We understand that the composting operation has a permit issued by Colusa County.  Composting operations that have the potential to degrade water quality are also subject to regulation by the Regional Board.  If the composting facility is designed to provide complete containment of the compost and any leachate, then WDRs may be waived under certain circumstances.  However, we have not been asked to review your compost facility design so we must presume that there is some potential for a threat to water quality.

Second, the wastewater discharge from Colusa Mushroom as proposed would violate the WDRs as specified below:

• 1. Discharge Prohibition A.5 prohibits discharge of wastewater to the designated land disposal areas between 1 November and 30 April each year.  However, Colusa Mushroom will generate wastewater from the composting system year-round and you propose to irrigate during the rainy season.
• 2. Discharge Specification B.4 limits the total dissolved solids (TDS) concentration of process wastewater to 700 mg/L.  Based on analytical data provided in the technical report, the Colusa Mushroom effluent can be expected to have a TDS concentration of 5,000 mg/L, approximately seven times the allowable concentration.
• 3. Discharge Specification B.5 limits the organic nitrogen concentration of wastewater discharged to the industrial wastewater pond and designated land disposal areas to 20 mg/L.  Based on the analytical data provided, the organic nitrogen concentration will be approximately 600 mg/L or 30 times the allowable concentration. We understand that you propose to dilute the wastewater as needed to comply with the effluent limitations and the land disposal area loading limits for biochemical oxygen demand (BOD) and nitrogen.
• 4. We are also concerned about the level of total coliform organisms measured in the wastewater samples.  Because chicken manure is used in the composting operation, there may also be salmonella species present in the wastewater.  Groundwater beneath the designated land disposal area is reportedly as shallow as five feet below the ground surface.  Therefore, it is unclear whether the designated disposal area will be capable of providing adequate filtration to prevent groundwater degradation by these microorganisms.
• 5. Finding 6 of the WDRs envisions a flow of up to 27,000 gallons per day (gpd) to the west emergency evaporation/percolation pond from November through April for winter storage until the next irrigation season.  However, at 5,000 gpd raw wastewater flow and 30 to 1 dilution, the Colusa Mushroom discharge to the west pond would total 150,000 gpd.

Therefore, the proposed discharge from Colusa Mushroom cannot be approved under the current WDRs.

If desired, you may apply for revised WDRs to allow year-round wastewater treatment, storage, and/or disposal.  However, please be advised that you must submit a complete revised Report of Waste Discharge (RWD).  The RWD must specifically show how all wastewater will be treated, stored and disposed, and how the proposed system will prevent groundwater degradation.  Once the RWD is determined to be complete, it will take up to 120 days before tentative WDRs can be brought before the Regional Board for their consideration.

Violation of WDRs
In preparing this response to your request, staff contacted the Colusa County Environmental Health Department and the Colusa County Air Pollution Control District.  Based on these communications, we understand that there have been numerous complaints about odors originating at the Colusa Mushroom facility since the compost operation began and that complaints were received as recently as 21 July 2003. These complaints are evidence that CIP has violated the WDRs.  Specifically, Discharge Specification B.1 states that neither treatment nor discharge of wastewater shall cause a nuisance.

Therefore, CIP shall take immediate steps to abate all conditions that are creating nuisance orders.  However, as stated above, the wastewater in the sump may not be discharged to the west pond or the designated land disposal area unless and until revised WDRs are adopted.

Request for Technical Report
In order to ensure that CIP takes all necessary actions to abate nuisance odors, by 15 August 2003, CIP shall submit a technical report describing the following:

• 1. All actions taken to treat and/or dispose of the wastewater in the sump;
• 2. All other actions taken to prevent and control odors associated with the compost operation; and
• 3. A specific interim plan for management and disposal of Colusa Mushroom’s wastewater that does not violate the WDRs.

The report shall bear the certification statement requirement by the Standard Provisions and Reporting Requirements.  If the wastewater is taken off-site for disposal, the disposal facility must be appropriately permitted to accept the waste, and the report must include documentation of the disposal site name, contact information, and receipts.

If you have any questions about this letter or would like guidance on preparing a Report of Waste Discharge, please call Anne Olson at (916) 255-3140.

WENDY WYELS, Chief
Waste Discharge to Land Unit

cc: Jaime Favila, Colusa County Department of Environmental Health, Colusa
 Charles Price, Colusa County Air Pollution Control District, Colusa
 Steve Hackney, Colusa County Planning Department, Colusa
 Duncan Soldner, Colusa Mushroom, Colusa
 Peter Rude, CH2M Hill, Redding
 

home page