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Mr. Ben Hall - 5 26 May 2004 Musco Family Olive Company Outstanding Work Plan Submittals/Requests for Regional Board. The Plan in Musco proposes to withdraw the 1 November 2002 work plan,4 as characterizing the quality of groundwater upgradient of the LTU has proven problematic and is not necessary if the Plan is approved. Musco will complete the "original Work Plan and Addendum submitted to and approved by the Regional Board." Comment: The Plan does not cite the title or date of this original work plan and addendum. We assume this approved work will generate the complete.report characterizing background water quality due 6 September 2004. Characterization of background groundwater quality in the LTU vicinity is still necessary to the degree necessary to effect closure after Musco phases out the LTU discharge. With potential indefinite continued use of the 84-mg wastewater storage reservoir, and LTU closure, it is -also-still necessary to-assess the.'impact of-Musco'S`discharges`on—groundwatet and ,-as - results dictate, consider appropriate action in accordance with State Board Resolution 92- 49. Masco's current groundwater data set, unfortunately, contains many anomalies and` errors that unnecessarily further complicate evaluation of the site's already complex geochemistry. We will address this matter under separate cover. Musco requested a one-year extension to the 6 September`2004 deadline in Cleanup and Abatement Order No.-R5-2002-0149 for achieving full compliance with Effluent Limitation C.1 of the WDRs, which sets numerical limits for total dissolved solids, sodium, and chloride. Musco indicates it is unreasonable to comply with limits that are dependent upon a characterization of background groundwater quality that will not be complete (Provision G.2.j of the WDRs) before then. The Plan now indicates that the numerical limitations should be determined through implementation of the flan. Comment: Based on information available at the time of adoption and the strategy for achieving conformance with water quality policies, the WDRs.provided Musco an opportunity to prove that background water quality was poorer than projected at the time and thereby gain relief from the effluent limitation set to take effect on 6 September 2004. Based on information subsequently developed, as well as the concentrating effects of the disposal operation itself, in current judgment of Regional Board staff the effluent limitation that takes effect on 6 June is not adequately protective of water quality. In our view, Musco should not and cannot delay further'in exc'cuting salt control technology in addition to its source control measures. Hence, whether as an amendment to the WDRs or through implementation of the Plan, Musco must implement all feasible technology and satisfy the Regional Board that it has fully implemented best practicable treatment and control for salt to gain approval of its Plan. Hence, Musco should, as the Plan proposes, submit a Report of Waste Discharge addressing this and a reasonable schedule and withdraw its request for a one-year extension. The Plan indicates Musco still wishes to pursue its request that the Regional Board regulate the organic and inorganic solids in its discharge separately. 4 Workplan Additional Hydrogeologic Investigation, Monitoring Well MW-9r, and Pan Lysimeter Installation, Sampling, and Reporting, prepared by Kleinfelder