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Ben Hall -8- 22 November 2006 <br /> Musco Family Olive Company <br /> 16. MRP No. R5-2002-0148 requires, in the second paragraph of Land Application Area <br /> Monitoring, the following:. <br /> "By 1 October 2002, the Discharger shall install a sufficient number of meters to <br /> continuously monitor the flow out of the settling/storage ponds to the land application <br /> areas. No wastewater shall be applied without metering. if portable pumps pre used to <br /> discharge wastewater to the land application area or a storage pond, additional meters <br /> shall be installed at every discharge point." <br /> The monthly monitoring reports reviewed state (in the Calculation.Methods note to the <br /> BOD and Nitrogen Loading Log Book) that the "GPF [gallons per field] is calculated by <br /> multiplying sprinkler minutes by the sprinkler output rating at.our operating pressure...,For. <br /> 95 acres, output is approximately 8.5 gpm, for lower acreage output is approximately 4.5 <br /> gpm [sic] Sections 95-01, 03, 05, 06, and 19 output is now 4.5 gpm". <br /> The Discharger's failure to use meters to measure flow to the application areas, as <br /> confirmed during the 12 October 2006 inspection, is a violation of WDRs Order No. <br /> R5-2002-0148. <br /> 17. WDRs Order No. R5-2002-0148 includes Provision GA, which requires compliance with <br /> Standard Provisions and Reporting Requirements for Waste Discharge Requirements, <br /> dated 1 March 1991 (Standard Provisions). - Standard Provision B.1 states, in part, the <br /> following: <br /> "In the event the discharger does not comply or will be unable to comply with any <br /> prohibition or.limitation of this Order for any reason, the discharger shall notify the Board <br /> by telephone...as soon as it or its agents have knowledge of such noncompliance or <br /> potential for noncompliance, and shall confirm this notification in writing within two <br /> weeks. The written notification shall state the nature, time and cause of noncompliance, <br /> and shall include a timetable for corrective actions." <br /> Written and verbal notification of Regional Water Board staff regarding violations has, with <br /> the exception of the monthly monitoring report transmittal letters, generally not occurred <br /> for at least the period reviewed. Failure to notify Regional Water Board staff in <br /> accordance with Standard Provision GA is a violation of WDRs Order No. R5-2002-0148. <br /> 18. Cleanup and Abatement Order No. R5-2002-0149 includes Item 4, which states that "[b]y <br /> 6 September 2004, the Discharger shall comply with all aspects of WDRs Order No. <br /> R5-2002-0148." As detailed above, the Discharger is in violation of WDRs Order No. <br /> R5-2002-0148 and is, therefore, also in violation of Cleanup and Abatement Order No. <br /> R5-2002-0149. <br /> While we appreciate, and are in the process of reviewing, Musco's long-term conceptual <br /> compliance plan (dated 13 September 2006), short-term remedies are available for many of <br /> the violations cited above. Therefore, please submit a technical report to this office by <br /> 22 December 2006 addressing all of the above violations that are not explicitly considered in <br /> the long-term conceptual compliance plan. The report should include an explanation of the <br />