SITE INFORMATION AND CORRESPONDENCE

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• ,jvlr. Benjamin Hall • -2 - • 25 September 2000 in the Board's 15 May 2000 correspondence, Musco is prohibited from using natural drainage ways to control surface water runoff. • To allow evaluation of the`water balances,pond acreage must be added to all water balance tables. • It is unclear whether or not analytical sensors will be placed in sumps at the factory site. • The report states preparation of new irrigation areas for land application will be performed in accordance with the recommendations of an agronomist. However, this information was not submitted. Because the reports were required for preparation of new Waste Discharge Requirements (WDRs), agronomist recommendations shall be included in the report. • Figure 4 indicates 100 acres of new irrigated pasture but the area indicated is much less than the existing 50 acres of irrigation shown on the same figure. The figure must be corrected. • The well construction proposed in the groundwater monitoring section of the report is not approved, however, the well locations proposed are acceptable. The well installation procedures require clarification as described below in the monitoring well workplan discussion. Comments on the monitoring well installation proposed are addressed below as part of the review of the 7 September 2000 HDR report titled,Revised 1-Mgal Pond Monitoring Well Workplan. • A description of the tailwater control and piping arrangements is required. EVAL UA TION OF EFFECTS OF LAND APPLYING PROCESS WATER The evaluation of the effects of the land application of wastewater is incomplete. The following items will need to be further addressed: • The Certified Crop Advisor (CCA)report was contained in Appendix C. The CCA report did not address all the items listed in the 15 May 2000 request for a technical report. The evaluation did not address operational specifics such as the irrigation schedule and sprinkler moving intervals.. The CCA report did not address the brown areas observed during the 10 May 2000 aerial inspection, crop problems identified upon close field inspection, water usage of existing and recommended crops, and the long term impact to soil and plant quality of the wastewater application. • A schedule for installation of the waste stream concentration reduction equipment was not provided. It is noted that the goal of a fixed TDS concentration of 1,500 mg/1 is above the fixed TDS limit presented in WDRs Order 97-037 Discharge Specification B6. In addition, Table 1 presents analytical data which characterizes the water discharged to the land application areas. The average concentration of fixed TDS is reported to be 1,987 mg/l, well above the existing WDR limit. Musco Olive is operating in violation of the existing WDRs. REVISED 1-MGAL POND MONITORING WELL WORKPLAN The installation of the groundwater monitoring wells requires submittal of additional material clarifying the workplan. In general the workplan was not prepared in accordance with the guidance document transmitted in the 15 May 2000 correspondence titled,Items to be Included in a Monitoring Well CTry=t FHWSItaVAu ftI10915 R[,