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Ben Hall -2- 21 November 2006 Musco Family Olive Company • Discharge Prohibition A.3 (both inspections), which prohibits the "[b]ypass or overflow of unscreened waste, or overflow of untreated or partially treated waste". • Discharge Prohibition A.7 (both inspections), which prohibits the "[I]and application of wastewater to any LTU [land treatment unit] not having a fully functional tailwater/runoff control system." • Discharge Prohibition A.10 (23 March 2006 inspection), which prohibits the "[d]ischarge of wastewater to the `irrigation checks' (a total of 8.9 acres)...unless the Discharger can prove the Executive Officer's satisfaction that the application of wastewater to this land will not result in objectionable offsite odors". • Land Application Area Specification D.14 (both inspections), which requires that "[d]ischarges to the land application area shall be managed to minimize both erosion and runoff from the land application area." As described in the enclosed inspection report for the 12 October 2006 inspection, Regional Water Board staff observed standing, and sometimes fermenting, water in sumps, tailwater return ditches, and erosion rills at various land application areas/land treatment units throughout the site. Large numbers of flies were observed clustered about the edges of several sumps and the eucalyptus grove. Tailwater conveyance, storage, and return systems functioned poorly and were inadequate to allow for proper drainage of the fields. Given i assertions by.Musco staff that no wastewater had been applied for two to three days prior to the inspection, it appears that applied irrigation water did not infiltrate completely within 24 hours, as required by the WDRs. While a grass crop (NyPa Forage) has been planted on two- foot centers on the application areas, the grass does not appear to be actively growing on the majority of the fields receiving wastewater. The following violations of WDRs Order No. R5-2002-0148 were observed during the 12 October 2006 inspection: • Discharge Prohibition A.7, which prohibits the "[I]and application of wastewater to any LTU [land treatment unit] not having a fully functional tailwater/runoff control system." • Discharge Specification 6.6, which prohibits the "discharge to conveyance systems, settling basins, ponds, or land application areas not adequately maintained to prevent off-site odor nuisance, fly breeding, or mosquito breeding". • Discharge Specification B.11, which requires the Discharger to "...operate all systems .and equipment to maximize treatment of wastewater and optimize the quality of the discharge." • Land Application Area Specification D.2, which states, in part, that "[c]rops shall be grown on the application area,"