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e. <br /> Ben Hall -5- 14 December 2006 <br /> Musco Family Olive Company <br /> a <br /> Section 6 of the Pilot Study Report concludes that "[t]he initial investment and the significant <br /> ongoing operating costs for treatment are not likely to be economically feasible for Musco, <br /> given the company's financial and operating cost structure." Based on a review of the Pilot <br /> Study Report and Treatability Study, Regional Water Board staff believe that insufficient data <br /> and pretreatment options have been researched to support Musco's conclusion that a full-scale <br /> treatment plant is economically infeasible. <br /> Musco has proposed to submit a report of waste discharge (RWD) in January 2007. The RWD <br /> must address the serious compliance issues facing Musco. We are particularly concerned <br /> that, should the NyPa Forage effort prove to be inadequate, completely ruling out treatment <br /> may leave Musco without the ability to discharge to the land treatment areas in compliance <br /> I with Waste Discharge Requirements Order No. R5-2002-0148. We encourage Musco to <br /> evaluate additional means of compliance, including treatment and Title 27 containment, and to <br /> include the results of this evaluation in'the proposed'RWD. - <br /> As requested above, the referenced initial testing, including mass balances on sodium, <br /> chloride, and total and fixed dissolved solids must be submitted 31 January 2007, as well as a <br /> discussion of the anticipated effect(s) of precipitation and sprinkler irrigation on retention of <br /> salts in the NyPa Forage foliage. <br /> If you have any questions regarding this letter, please contact Melissa Hall at (916) 464-4757. <br /> STEVE ROSENBAUM <br /> Senior Engineering Geologist <br /> Land Disposal Unit <br /> Lower Sacramento River Watershed <br /> CC' Eileen Jones, United States Bureau of Reclamation, Tracy <br /> Lori Oldfather, California Department of Fish and Game, Stockton <br /> Carol Oz, California,Department of.Fish and Game, Rancho Cordova <br /> Joe Spano, California *Department of Health Services,Stockton` <br /> Marissa Nishikawa, California Department of Transportation, Fresno <br /> Charyce Hatler, California Department of Water Resources, Fresno <br /> David Irey, San Joaquin County District Attorney, Stockton <br /> Donna Heran, San Joaquin County Environmental Health Department, Stockton <br /> Rick Gilmore, Byron-Bethany Irrigation District, Byron <br /> Bill Jennings, California Sportfishing Protection Alliance, Stockton <br /> Dennis Leikam, Musco Family Olive Company, Tracy <br /> Gary Carlton, Kennedy/Jenks, Rancho Cordova <br /> Alson Brizard, Groveland <br /> Paul Harpainter, Tracy <br />