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t California Regional Water Quality` � t; c �- rd : Central Valley Region cif' _. Robert Schneider,Chair Q4 MA Y 2$ pM 6 k °" Terry Tamminen Fresno Branch Office Arnold 5chwarzenegger Secretaryfor Internet Address: bttp://www.swrcb.ca.govhrwgcbS Governor Environmental 1685 E Street,Fresno,California 93706-2020 Protection Phone(559)445-5116•FAX(559)'445-5910 26 May 2004 Mr. Ben Hall Mr. Nick Musco Musco Family Olive Company Studley Company . 17950 Via Nicolo 17950 Via Nicolo Tracy, CA 95376 Tracy, CA 95376 CONCEPTUAL.CO.MPLIANCE PLAN,.MUSCO FAMILY OLIVE COMPANY, SAN JOAQUIN----= COUNTY The 23 February 2004 le er by Mr. Michael Campos of Stoel Rives LLP on behalf of Musco Family Olive Company(Musco) describes a Conceptual Compliance Plan (Plan). The Plan outlines short- and long-term goals for Musco to achieve compliance, summarizes Musco's previous compliance plan, identifies the Plan's elements, recognizes environmental and treatment issues, discusses outstanding work plan submittals/requests to the Regional Board, and identifies several critical timing issues in implementing the Plan. The Plan contains five figures, including a map showing nearby potential reuse areas and two depicting general and specific implementation timelines. Musco has been engaged in addressing deficiencies in treatment and control of discharge of olive processing wastewater to a 200-acre land treatment unit (LTU) in order to obtain Regional Board approval for the long- term. Due to the site's complex hydrogeology and the uncertainty and expense of resolving all outstanding deficiencies, the Plan proposes instead to treat wastewater sufficient for unrestricted agricultural reuse and to phase out the LTU discharge over five years. In 15 to 20 years, when the general area around proposed reuse areas is projected to be developed, Musco proposes to connect to a regional wastewater treatment facility(WWTF) that the City of Tracy anticipates constructing to serve development. Effluent from the regional WWTF will likely be recycled on greenbelts, golf courses, and parks. The Plan proposes that Musco then discharge all of its wastewater to the regional WWTF, except for what may be used industrially, `and discontin—ue all other larici discharge, including diseharge to the 84-rng reservoir: Plan Elements. Musco is currently negotiating with the owners of farm properties comprising about 600 acres within Plan View Irrigation District to develop lease agreements for the delivery and agricultural use of Musco's recycled water. Groundwater underlying these properties is believed to contain total dissolved solids in concentrations ranging from 1,400 and 1,800 mg/L. A thorough characterization of groundwater in the new discharge area will be necessary to determine the extent to which, if any, treatment for salt removal will be required. Musco has obtained approval to test the surface soils and groundwater underlying the properties. Without the complex hydrogeology of the Musco site, characterization of groundwater underlying valley floor reuse areas should be a relatively straightforward undertaking. With respect to recycled water conveyance facilities, Musco plans to construct a new trunk line to convey recycled water to existing canals and distribution lines owned by Plan View Irrigation District and the District will convey the recycled water to parcels under lease agreement. Musco is also evaluating the California Environmental Protection Agency Recycled Paper