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Mr. Benjamin Hall - 3 - 12 July 1999 capacities. Although not specified in the MRP, it would be preferred if future reports indicate flow # rate to each individual pond. 5. The reports for the surface water moniioring do not indicate the temperature, flow rate, total suspended solids,nor Chemical Oxygen Demand (COD) as is required in the MRP. These parameters shall be conducted as required in the MPR unless rationale is presented to indicate that they are not useful and the MPR is then revised. 6. Annual parameters for the "Production Water" from the Musco Olive Well No. 1 were reported with the exception of COD and groundwater elevation. COD and elevation are specified in the MRP as j background monitoring parameters. Please ensure tliat these parameters are included in future annual sampling and analyses. To reiterate, reporting of COD and groundwater elevation is a requirement of WDR-Order No. 96-075. Comments Specific to MRP 97-037 (Water Reclamation Project - 1 1. The label on the top of the summary table should refer to MRP 97-037 rather than 87-132. 2. Biochemical Oxygen Demand (BOD) should be analyzed on a monthly basis. BOD was included for February,but not for January or March. This parameter is a required parameter according to MRP 97-037. 3. The WDR 97-037 "Discharge Specifications" indicate a BOD annual average loading rate of 100 lbs/acre/day. Musco should calculate and report the BOD annual average loading rate so that direct comparisons may be made. 4. Sodium and chloride are required to be analyzed on a monthly basis and should be included on the summary tables that Musco submits. Laboratory data sheets that included analytical reports for both sodium and chloride were only included for samples collected on 8 February 1999. General Minerals are to be.tested on a quarterly basis and were not included in the first quarter package. 5. The reported values-of Dissolved Inorganic Solids (DIS) are much higher-than.the Daily Maximum Loading Rate as specified in the WDR 97-037 "Discharge Specifications". During our telephone conversation on Tuesday, 6 July 1999, you indicated that these numbers are unusually high and that you have been concerned. You also indicated that nothing had changed in the olive production process,but that you would reevaluate the situation once olive processing begins again in the fall. 6. The annual average loading rate for DIS as specified in the WDRs is 1264 mg/I. Musco reports a running average DIS of 1,197 mg/l in March 1999, despite much higher weekly DIS values reported for the entire first-quarter of 1999. During our telephone conversation on 6 July 1999, you indicated that DIS values in the early fall are very low because during the olive harvest, olive wash water routed to the reclamation storage pond is a significant volume and contains very low DIS. The MRP for the reclamation project indicates also that soil sampling at ten randomly selected areas that received irrigation water is to be conducted on an annual basis. Because I have reviewed only the report of the first quarter of 1999, 1 am not aware of the time period that the soil sampling will occur in. Please telephone or write by 30 July 1999 indicating the date of the soil sampling.