SITE INFORMATION AND CORRESPONDENCE

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CLEANUP AND ABATEMENT ORDER NO. 5-00-717 - 2 - MUSCO OLIVE PRODUCTS AND THE STUDLEY CORPORATION MUSCO OLIVES PRODUCTS,TRACY FACILITY SAN JOAQUIN COUNTY 6. Because the volume of the storage pond is inadequate to hold more than two days of wastewater, the Discharger applies wastewater to the fields even during rainfall events. The Discharger assumes that the soil will retain the wastewater and rainfall, and therefore prevent the discharge of waste. However, staff received complaints of wastewater running onto the neighboring properties in 1997. In addition, a May 2000 inspection, following a rainfall event, found that wastewater was flowing off the land application area into a seasonal drainage and then off the property. 7. On 15 May 2000, the Discharger was issued a Notice of Violation for inadequate wastewater handling, storage, and application procedures observed on 8 May and 10 May 2000. During the site inspection, evidence of the one million gallon pond overtopping and wastewater escaping the site in surface water drainage courses was observed. A review of self-monitoring reports also showed that the Discharger was discharging wastewater in violation of the effluent limits contained in Order No. 97-037. The items listed in the Notice of Violation were: a. Wastewater was observed discharging below Pond No. 3. The Discharger had no control of surface water flow below this pond. The WDRs require all production wastewater to be confined at all times to property owned or controlled by the Discharger. b. The Discharger applied process wastewater to land during rain events, in violation of the WDRs. c. The Discharger allowed wastewater and stormwater to flow directly into a natural drainage course in violation of the WDRs. d. The Discharger discharged process wastewater to ponded surface water and discharged wastewater to an area within 100 feet of surface waters. e. The Discharger applied process wastewater to land that had concentrations of DIS which exceeded the limits presented in the WDRs. The limits for DIS are 1,264 mg/1 annual average and 1,340 mg/1 daily maximum. The average DIS concentrations reported by the Discharger in the first quarter of 2000 all exceeded 2,000 mg/l. The daily maximum criterion has also been exceeded in all the reported sample events for the first quarter of 2000. 8. The 15 May 2000 Notice of Violation required the Discharger to come into compliance with the existing WDRs forthwith and submit a report showing how it had come into compliance. The Discharger submitted a report on 9 June 2000 stating all irrigation tailwater was contained on it's property and that a consultant had been retained to develop a wastewater management plan.. 9. On 15 May 2000, the Discharger was issued a request to submit reports pursuant to Section 13267 of the California Water Code. The technical reports were required to supplement the Report of Waste Discharge and address wastewater storage issues, application procedures, contaminant concentration limits, the impact of applying wastewater to cropland, and alternatives for source control procedures at the facility that were described in the 15 May 2000 Notice of Violation. 10. On 14 July 2000, the Discharger submitted a groundwater monitoring report which was deemed inadequate; the workplan was resubmitted on 7 September 2000. The Discharger submitted two additional reports: Storage Facility Improvements on 8 August 2000, and Evaluation of Effects of Land Applying Process Water dated 28 August 2000. The reports were determined to be incomplete. While the Discharger has made some steps at addressing the situation (proposes construction of a 72-million gallon pond, collection trenches to control wastewater and surface water mixing, and a tailwater pump station), the reports do not contain all the information required ( Pnr.:G I'ilu,alwa Divaoa.AOR-.Le