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7a California Regional Water Quality Control Board Central Valley Region Linda S.Adams Arnold Secretaryfor Schwarzenegger Environmental Sacramento Main Office Governor Prorechon 11020 Sun Center Drive 11200,Rancho Cordova,California 95670-61.14 Phone(916)464-3291 •FAX(916)464-4645 http://www.waterboards.ca.gov/ceniralvalley nD WEPE�WED '14 December 2006 Ben Hall, Director Environmental Services and Programs DEC 1 '9 2006 Musco Family Olive Company, 17950 Via Nicolo SAN JOAQUIN COUNTY Tracy, CA 95377-9767 EIIViRONMENTAL HEALTH DEPT AMENDED CONCEPTUAL COMPLIANCE PLAN, MUSCO FAMILY OLIVE COMPANY AND THE-STUDLEY COMPANY, SAN JOAQUIN COUNTY, WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2002-0948 We have reviewed your Amended Conceptual Compliance Plan (Compliance Plan), dated 13 September 2006. The Compliance Plan examined potential compliance options, including the use of NyPa Forage to achieve a net reduction of salts in site soils, source reduction, a new process, enhanced evaporation, the use of NyPa Forage as a bio-fuel, discharge to the City of Tracy's wastewater treatment plant, and direct discharge to the Sacramento River from the Orland facility. The Compliance Plan also contained several requests. Specifically, the Plan requested an extension of the deadline for compliance with final effluent limitations under Cleanup and Abatement Order No. R5-2002-0149, a response to the 15 August 2003 Assimilative Capacity Workplan, and separate regulation of inorganic and organic dissolved solids. These requests are under review and will be addressed separately. i In general, we appreciate Musco's efforts with respect to source control and encourage Musco to focus its resources on those.elementslcompliance measures fully within Musco's control, e.g., source reduction and the proposed enhanced evaporation systems. Compliance measures outside of Musco's full control (e.g., cogeneration facility, discharge to other locations) lack an acceptable measure of certainty. The Regional Water Board has recently expressed serious concerns about increasing salt loading to the Delta. Discharges of process wastewater of the current quality from the Musco facility either to the City of Tracy's _ wastewater treatment plant (if discharging to surface water) or to the Sacramento River (or one of its tributaries) would result in increased salt loads to the Delta. Musco representatives acknowledged, during our 4 October 2006 meeting, that a discharge to the City of Tracy's wastewater treatment plant would require pretreating process wastewater to a level comparable to what would be achieved had the proposed reverse osmosis treatment been implemented. The Compliance Plan does not address this issue. The Compliance Plan stated that Musco plans to use NyPa Forage to remove sodium and { chloride from site soils. The NyPa Forage would be harvested and sold as cattle feed, thereby removing the salt from site soils. The Compliance Plan referenced the NyPa Distichlis Cultivars: Rehabilitation of Highly Saline Areas for Forage Turf and Grain California Environmental Protection Agency Recycled Paper i