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Ben Hall • • <br /> Musco Family Olive Company 2 7 May 2007 <br /> As described in the enclosed inspection report for the 14 April 2007 inspection, Regional Water <br /> Board staff observed dark liquid pooled near the million-gallon pond and dark staining of soil <br /> on the hillside below the million-gallon pond. In a follow-up conversation with Kelly Hegman of <br /> your staff, Mr. Hegman stated that Musco personnel had recently been emptying barrels of <br /> vinegar into the million-gallon pond and that some of the barrels had leaked. The spill of <br /> vinegar (source of acetic acid) violates the following requirements contained in WDRs Order <br /> No. R5-2002-0148: <br /> • Discharge Prohibition A.3, which prohibits the "[b]ypass or overflow of unscreened <br /> waste, or overflow of untreated or partially treated waste". <br /> • Discharge Prohibition A.6, which prohibits the "[d]ischarge of process water to areas <br /> other than the designated LTUs [land treatment units] described in the "Land Application <br /> System"section of the Findings". <br /> • Land Application Areas Specification D.9, which requires that "[t]he discharge of <br /> process wastewater...shall not occur outside the boundaries of the land application <br /> areas." - <br /> We note that the March 2007 monitoring report included a statement that "Musco is currently <br /> working on the installation project for metering the tailwaterlstormwater return from all of the <br /> newly installed steel lined collection sumps to the MGP." We expect that the identified and <br /> threatened violations can be corrected in the near term. We request that Musco submit a <br /> technical report to this office by 8 June 2007. The report should include a short-term <br /> corrective action plan to address each violation listed above. The report should also propose <br /> changes to the facility's operation and maintenance plan (Provision G.2.e of the WDRs) to <br /> prevent such violations in the future. <br /> If you have any questions regarding this letter, please contact Melissa Hall at (916) 464-4757. <br /> STEVE E. ROSENBAUM <br /> Senior Engineering Geologist <br /> Land Disposal Unit <br /> Lower Sacramento River Watershed <br /> Enclosures: Inspection Report for 6 April 2007 Inspection (including analytical results) <br /> Photograph Log for 6 April 2007 Inspection <br /> Inspection Report for 14 April 2007 Inspection (including analytical results) <br /> Photograph Log for 14 April 2007 Inspection <br /> cc list next page <br />