SITE INFORMATION AND CORRESPONDENCE

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Ben Hall -2- 5 November 2007 Musco Family Olive Company wastewater and runoff information is routinely collected at the site, but Kennedy Jenks needs to ensure that sufficient data is collected to meet the data quality objectives for this study. Under the first bullet item of Section 3.1 of the Work Plan, ash content is noted as a surrogate for fixed dissolved solids. This item also states that general minerals will be analyzed for one harvest per test plot per year. Kennedy Jenks needs to establish the nature of the correlation between ash content and specific cations and anions at the beginning of the study to ensure useful and understandable results. Under the second bullet item of Section 3.1, the analyte list for root zone soil sampling needs to include, at a minimum, those constituents listed in Item 12 on page 18 of the Cease and Desist Order. For example, bicarbonate is a key constituent of Musco's wastewater, but it is not discussed in the Work Plan. Its fate in the environment may differ from the other salts and needs to be addressed. The appropriate constituents need to be added to the analyte lists and included in the data evaluation Under Section 3.2 Study Locations, Kennedy Jenks describes three locations for the test plots and an unspecified number of additional monitoring locations for soil water monitoring and flux analyses. At least one test plot should be added in an area where tailwater and stormwater pond in the vicinity of the sumps or mud boxes (e.g., at the toe of Field 95-20). While these areas are small and do not represent the land application area as a whole, we believe they do represent the areas of highest flux due to saturated soil conditions. The activities proposed in the Work Plan may proceed provided Musco and Kennedy Jenks address the above factors as the work begins. Additional Concerns We identified the following concerns in our review of the Work Plan and believe they need additional consideration by Kennedy Jenks. While the Work Plan proposes methods to assess moisture and waste constituent distribution in the soil column, it does not propose to assess the actual total and remaining assimilative capacity of the soil. The Work Plan must propose work necessary to comply with Task 12 of CDO No. R5-2007-0139, including preparation of a salt balance. In addition, it needs to discuss how the chemical and physical characteristics of the soil affect the fate and transport of the constituents of concern (i.e., nitrogen compounds, bicarbonate, sulfate, iron, sodium, chloride, volatile/organic dissolved solids, etc.). For example, the annual soil monitoring results submitted to our office show that sodium is accumulating in at least the upper six inches of soil. Chloride, however, despite the discharge to,land of approximately 260 tons in 2005 and approximately 400 tons in 2006, does not appear to be accumulating at any of the three soil depths currently monitored. As chlorideis neither degraded nor transformed in the soil column, the Work Plan must be revised to explain how you intend to evaluate the fate of chloride at the site. This is critical in light of the Soil Profile and Agronomic Report for 2006, dated 31 January 2007, which stated that "[b]ased on sodium and chloride in NyPa forage samples, removal of more salt than applied is not projected." The Work Plan needs to be revised to include a salt balance, an assessment of the assimilative capacity of the soil for specific waste constituents, and a discussion of how chemical and physical characteristics affect constituent fate and transport.