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Mr. Ben Hall - 4 - 26 May 2004 Musco Family Olive Company Plan's identified measures and the characterization of the salt content in irrigation supply currently utilized in the proposed reuse areas. Additional water use for rinsing and process changes that improve the result is acceptable, but additional water solely for the purpose of diluting salt concentration could be considered a waste and unreasonable use of water. The final proposal should consider this distinction and also evaluate the extent to which, if any, additional wastewater storage capacity is required to accommodate the increase in discharge flows. The Plan suggests that Musco may propose BOD levels exceeding those typical of secondary treatinent.Z As we advised Musco during our meeting on 27 January 2004, "recycled water" used in the manner proposed by the Plan (and as defined in California _ �_ Water�CoderSe�tion 13050(ir).),refers=to w�stewater_subjected tQ-s-cfondarv-treatment-of m _ conventional pollutants to render it suitable for direct beneficial use.3 If the discharge of wastewater to offsite agricultural land is to be a"recycled water project," conventional waste constituents must be subjected to secondary treatment. Users of wastewater treated to this degree will be subject to minimal regulation, Recycling of secondary-treated wastewater is regulated by water recycling requirements that require monitoring typically limited to hydraulic and nutrient loading, crop type, and planting schedule: A project involving wastewater subjected to less-than-secondary treatment relies upon further treatment after land application and users will need to obtain individual waste discharge requirements requiring regular monitoring of discharge quality,waste constituent loading, groundwater quality, and, increasingly, percolate quality, to confirm that the soil's assimilative capacity has not been exceeded. In addition, the potential of creating nuisance in conveyance facilities must be mitigated. If Musco plans to continue using the 84-mg wastewater storage reservoir until the regional WWTF is available, it must implement measures to preclude unacceptable groundwater degradation from the impounded wastewater. These measures may include lining the reservoir, as required by Task 16 of Revised Time Schedule Order No. R5-2002-0014- RO1, and/or subjecting the wastewater to treatment prior to impoundment to control �. -��"�groundwater dz`grrafdation fr-om ifforgarii- sc an-ddecomposifionbyp odu is ds necessary; to what the Regional Board authorizes. Secondary treatment facilities reflecting decades-old technology typically produce an effluent with monthly average daily and daily maximum concentrations of biochemical oxygen demand (BOD) and total suspended solids (TSS) each not exceeding 30 and 45 mg/L, respectively. Facilities reflecting current treatment technology typically produce an effluent with Iess than 20 mg/L each of BOD and TSS. 3 The Water Code does not define the minimum level of treatment necessary for a wastewater to be considered recycled water. However, undisinfected secondary is the minimum required level treatment of wastewater of domestic origin for purposes that do not require pathogen removal, according to State's Water Recycling Criteria(as established in Title 22, California Code of Regulations, Section 60301 et seq., or"Title 22"). Undisinfected secondary recycled water is defined as "oxidized wastewater" (Title 22 Section 60301.900), which is defined as "wastewater in which the organic matter has been stabilized, is nonputrescible, and contains dissolved oxygen" (Title 22 Section 60301.650). Secondary treatment is the minimum level of treatment capable of consistently and reliably producing a wastewater with this requisite quality.