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Ben Hall -3- 21 November 2006 Musco Family Olive Company i Land Application Area Specification D.13.a, which requires that "[a]11 applied irrigation water must infiltrate completely within 24 hours." Land Application Area Specification D.14, which requires that "[d]ischarges to the land application area shall be managed to minimize both erosion and runoff from the land application area." f Land Application Area Specification D.15, which requires that "[t]here shall be no standing water in the land application areas 24 hours after wastewater is applied, except during periods of heavy rains sustained over two or more consecutive days." On 27 October and 3 November 2006, Musco submitted updates to Regional Water Board staff (via electronic mail) regarding recent improvements to the tailwater control system. Improvements made as of the most recent update included installation of mud boxes in fields 18 North, Evaporation South, North Spur, Park West, South Ridge East, and the lower portion of 55 East; installation and wiring of Christy boxes for all mud boxes except for South Ridge East; improvements to the discharge plumbing for the mud boxes; electrical work on the eucalyptus grove mud box pump, and completion of a tailwater ditch for the western portion of the South Ridge field. The updates also described erosion control work, including consultation with an erosion control firm. We expect that many of the identified violations can be corrected in the near term and we appreciate the efforts that Musca is currently undertaking to correct these violations. We usco in believe the level of design, construction, operation,a Work with Musco to aintenance employed this by situat on. the past has led to these violations and we ' Our concerns include Masco's ability to maintain a crop in the spray disposal areas, to prevent stormwater pollution, and to control runoff from the facility. We anticipate these issues will be addressed in the report of waste discharge described in Musco's conceptual compliance plan and scheduled for submittal in January 2007. In the interim, we request that Musco submit a technical report to this office by 22 December 2006. The report should include a short-term corrective action plan to address each violation listed above. The report should also propose changes to the facility's operation and maintenance plan (Provision G.2.e of the WDRs), as well as the facility's stormwater pollution prevention plan (Provision E.2 of Water Quality Order No. 97-03-DWQ—general F industrial stormwater permit), to prevent such violations in the future. If you have any questions regarding this letter, please contact Melissa Hall at (916) 464-4757. STEVE ROSENBAUM Senior Engineering Geologist Land Disposal Unit Lower Sacramento River Watershed f r ,