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Ben Hall -2- 14 December 2006 � Musco Family Olive Company (http://www.rirdc.gov.au/reports/Ras/02-154.pd publication. Section 3.5.3 (page 22) of that publication includes the following: "However, where the salt taken up from the groundwater by the plant and exuded through the leaves is eventually deposited remains to be studied. It appears likely that the salt that blows away and falls again down wind, is washed away or enters the soil in the next rain, depending upon soil texture and intensity of the rain...The net effect over time is to increase the rate at which salts in the rising water table are released to wash away in early rains." We are not confident that the in-field efficiency of harvesting would be as high as what might be predicted by laboratory testing. In addition, while the NyPa publication seems to focus on increasing soil porosity and remediating shallow saline groundwaters, it does not discuss sodium anti cTilo id'e uptake ra es o s nnkfer irrigation:—The.Compliance Plan also referenced initial testing (page 2,-paragraph A.1) indicating that NyPa is capable of achieving a net removal of sodium and chloride from the Musco site soils. By 31 January 2007, please submit (a) the referenced initial testing and (b) mass balances on sodium, chloride, and total and fixed dissolved solids, including descriptions of assumptions regarding applied wastewater rates, runoff, infiltration, and NyPa Forage uptake and a discussion of the anticipated effect(s) of precipitation and sprinkler irrigation on retention of salts in the NyPa Forage foliage. The Compliance Plan submittal was accompanied by the Pilot Study Results Summary Report (Pilot Study Report), The Pilot Study Report discussed the treatability of selected olive processing waste streams using biological.treatment in a membrane bioreactor (MBR) with 0.04-micron ultra-filtration membranes and dissolved solids removal by reverse osmosis (RO). The pilot plant was sized for a treated discharge of 5 gallons per minute (7,200 gallons per day). The Executive Summary to the Pilot Study Report stated that "[tlhe treatment concept that the pilot study was conducted to evaluate involves segregating the wastewater streams with the highest inorganic strength and treating these streams using reverse osmosis (RO) to separate the dissolved inorganic constituents...The permeate from the two-stage RO membrane -treatment-would be-blended-with-other-screened process-wastewater-in-Musco's 84=million - gallon (MG) aerated reservoir, with the goal of producing effluent containing very low organic concentrations and less than approximately 1,200 mg11 of inorganic dissolved solids [fixed dissolved solids or FDS]." In Section 2.1, the Pilot Study Report explains that "[tlo create capacity in the existing impoundments to be used for managing the reject, treatment was designed to include process wastewater streams normally routed to the impoundments for management.", for a combined FDS of 6,000 mgll. The Executive Summary to the Pilot Study Report indicated that Musco staff were primarily responsible for the day-to-day operation of the pilot plant, including conducting monitoring and recording results. The study commenced in August 2003. Mechanical failures and operational issues resulted in the loss of the MBR biomass on several occasions, lengthening the study duration,to two years. The Pilot Study Report found that frequent and continuous fouling of the RO and ultra-filtration membranes resulted in reductions to the anticipated efficiencies of the treatment processes.