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e Ben Hail -4- 14 December 2006 Musco Family Olive Company unlikely this would be the sole reason for the higher concentrations that were reported." These documented concerns and discrepancies in sample collection and analysis do not inspire confidence in the usefulness of the analytical results in evaluating the effectiveness of the tested treatment system. b.. Inadequate Characterization and Equalization of Influent Wastewater i. The TFOG [total fats, oils, and greases] reported over the first month of the study were extremely high, ranging from less than 10 to over 400 mg/L. The values were considerably lower for the remainder of the study (typically less l an_10 mg/L).�.The membrane system did not seem to operate any differently. during the period with high oil and grease. Possible reasons for this include.- I., nclude:1., The-TFOG reported was primarily surfactant based 2. The results were inaccurate, and the actual TFOG was much lower. 3. Most or all of the TFOG was degraded in the bioreactor." ii. "It was difficult to grow biomass-at times, due to the wide variations of influent feed conditions. In addition, the system lost undetermined amounts of biomass on several occasions due to foaming episodes." iii. "There was a significant amount of TKN in the influent feed water, ranging from 44 to 220 mg/L...The influent Total Phosphorus was extremely variable, ranging from 1 to 415 mg/L, with an average of 41 mg/L." The lack of certainty regarding causes of operational disruptions and effects of influent quality and variability on the individual treatment units suggests an inadequate characterization of the waste streams to be treated hampered the ability to identify and prevent potential problems and to correct operational problems as they arose. Regional Water Board staff concur with the Treatability Study - recommendation-to-include equalization-in a full-scale treatment-system. Despite the documented challenges to operation, section 6.3 of the Treatability Study reported that the "Reverse Osmosis system achieved over 95% TDS removal, when comparing averages across the testing period.," Section 5 of the Pilot Study Report estimated conceptual-level capital costs for a process wastewater treatment plant at approximately $11 million and annual operations and maintenance costs at $1.68 million. Regional Water Board staff contacted a number of vendors to obtain rough-order-of-magnitude estimates for the cost of treating up to 800,000 gallons per day of process wastewater. The vendors were provided with influent characteristics based on data submitted as part of Musco's monthly self-monitoring reports. Vendor estimates of capital costs ranged from $3.25 million to $6 million.