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Mr. Ben Hall - 6 - 26 May 2004 Musco Family Olive Company Comment: Secondary treatment will reduce the discharge's organic solids to negligible amounts compared to its inorganic solids concentration, and this should make it less of an issue for Musco. More importantly, future waste discharge requirements will consider each waste constituent released by Musco and evaluate its potential impact on water quality and what treatment and controls are applied to the constituents that have potential to degrade groundwater. This constituent-by-constituent evaluation process will properly address the waste constituents that actually threaten groundwater. Finally, the Plan indicates Musco has not received a response to the 15 August 2003 report prepared by Kennedy/Jenks Consultants describing an LTU Assimilative Capacity Work Plan pursuant to Provision G.2.f of the WDRs. u- - Comment:_.As�y_ou know, the_Regional Board letter of-10 March_2004. o Mr.Miehael Campos, which was copied to you, responded to the report. It explained why the work plan was not adequate, as well as why an extension of the Provision G.2.f submittal deadline is not warranted. You have since replied with an 18 May 2004 letter from Kennedy/.leaks Consultants that contains a revised workplan, We will respond to it as soon as we can. Critical Timing Issues. The Plan includes a five-year schedule to phaseout discharge. The Plan indicates Musco intended to start replacing sodium salts with potassium salts by 1 March 2004 and to, within 18 months, reduce bicarbonate use (by increasing the volume of water used for rinsing). Musco also proposes to submit by 1 May 2004 a report describing results from investigation of soils and groundwater conditions in the vicinity of the proposed reuse areas. Comment: The proposed five-year period to phase out discharge to the LTU on its face seems excessive. Implementation of secondary treatment and acquisition of lease agreements with owners of reuse areas should, under optimum conditions, require less than two years. The actual proposal for a schedule for additional time must include adequate justification for the proposed schedule (i.e., anticipated time required for acquiring permit(s) for project implementation, costs of necessary treatment works and recycled water conveyance systems, and Musco's ability to pay, etc.). The switch to potassium must not cause discharge TDS to exceed permitted limits (i.e., 3,373 mg/L currently and 2,047 mg/L after 6 September 2004). Also, as this measure is expected to increase discharge flow by 40 percent and the,LTU does not have the capacity, the measure cannot be implemented until Musco installs the necessary secondary treatment works and secures authorization to recycle its wastewater on offsite reuse areas. The investigation should include a characterization of the quality of irrigation supply waters currently used on the proposed reuse areas. By September 2004, Musco plans to submit a Report ofWaste Discharge in support of a discharge of recycled water for agricultural use, and to initiate the discharge by September 2005 following adoption of water recycling requirements by the Regional Board. If the Regional Board is required to perform an environmental evaluation of the proposed discharge pursuant to the California Environmental Quality Act