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California Regional Water Quality flontrol Board vCentral Valley Region , a Robert Schneider,Chair Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swreb.ca.gov/—mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 FEB 1 9 2002 15 February 2002 ENVIRONMENT HEALTH PERMIL�&WED MAIL 7001 2510 0003 5225 8566 Mr. Nick Musco Studley Company 17950 Via Nicolo Tracy, CA 95376 REQUEST FOR REPORT PURSUANT TO SECTION 13267 OF THE CALIFORNIA WATER CODE, MUSCOOLIVEPRODUCTS, TRACY, SAN JOAQUINCOUNTY Musco Olive Products and the Studley Company operate an olive processing and canning facility near the City of Tracy. The facility generates wastewater with elevated concentrations of total dissolved solids, sodium, and chloride that is applied to land. Because this facility has been in violation of Waste Discharge Requirements (WDR) Order No. 97-037 and Cleanup and Abatement (C&A) Order No. 5-00- 717, I am considering issuing an Administrative Civil Liability Complaint (ACLC) for past violations. One factor that must be considered in preparing an ACLC is the economic benefit accrued through lack of compliance. In year 2000, Musco Olive Products expanded dramatically the processing operation in Tracy, nearly doubling the capacity of the facility. Much of the expansion has been attributed to the acquisition of Early California Foods (ECF) and transfer of the ECF processing facility from Visalia to Tracy. Musco Olive Products has stated that the ECF plant was expensive to operate, that resolution of wastewater issues were costly, and that distribution costs could be minimized through consolidation of the operation with the Tracy facility. Because Musco Olive Products' business decision to consolidate the operations at the Tracy facility resulted in significant savings,we are requesting information on the economic savings for the wastewater treatment and disposal that were realized as a result of combining the two processing facilities, and the savings realized by not constructing the wastewater treatment system to comply with WDRs Order No. 97-037 and C&A Order No. 5-00-717. Please provide cost estimates that describe both total project cost estimates and present value analysis of the costs to comply with the WDRs Order No. 97-037 and C&A Order No. 5-00-717. Please break down each estimate to describe capital costs and operation and maintenance costs, and include assumptions that explain the estimates including the level of treatment, financing costs, and interest rates. The cost estimates shall address the following: • Cost of pretreatment equipment and discharge fees at the ECF facility to process the crop acquired through Musco Olive Products' purchase of ECF; and California Environmental Protection Agency Cd Recycled Paper The energy challenge facing California is real Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/mgcb5