SITE INFORMATION AND CORRESPONDENCE

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Mr. Benjamin Hall • - 2 - • 15 May 2000 • Surface runoff was observed flowing down from the upper application area into a natural drainage course. Because of recent rain(on 6 and 7 May 2000), and the ongoing discharge of wastewater in this area, the runoff was likely a mixture of stormwater and wastewater. Application of wastewater during a rain event is a violation of WDR No. 97-037 as described below. • Pond No. 2 has been formed within the natural drainageway. It contains an automatic tailwater return pump which directs tailwater back to Pond No. 1. The embankment and pumping station is inadequate to control the flow of tailwater, as evidenced by flow downstream of Pond No 2's embankment. • A second embankment forming Pond No. 3 was constructed across the surface drainage course downstream of Pond No. 2. A manually operated diesel powered pump was pumping wastewater to sprinklers located in the 50-acre future land application area. The liquid pooled behind the embankment contained a considerable amount of untreated wastewater. • Surface runoff of wastewater pumped from Pond No. 3 and applied to the 50-acre application area drains to the natural drainage course below Pond No. 3. This wastewater leaves the site, as described below. • Culverts installed in Pond No. 3 allowed wastewater to flow into the area downstream of the embankment. Heavy growth of vegetation was observed in the drainage area downstream of Pond No. 3. Pooled water was also observed at the culvert which allows water to drain under Highway 580. The 10 May 2000 aerial inspection showed that wastewater flows off the Musco property. This condition is a violation of WDR No. 97-037 as described below. • Stormwater which falls on the brine tank area concrete pad is discharged to a sump equipped with an electrical conductivity meter. The meter controls a switch which directs the wastewater to the lined Class II impoundments or Pond No. 1 based on the electrical conductivity of the wastewater. At the time of the inspection, you did not know at what concentration the switch activates. • Process wastewater has overflowed at the southwest comer of the brine tank farm and mixed with stormwater before flowing into Pond No. 3. • Portions of the application areas are too steep for the crop grown to be harvested. Presently, the land is leased to a cattle rancher. • Aerial photography of the Musco site, performed on 10 May 2000 revealed distressed vegetation in the 145-acre upper application area. The following violations of WDRs No. 97-037 were observed. • Wastewater was observed discharging below Pond No. 3. The Discharger has no control of surface water flow below this pond. Discharge Specification B.3 states, "The use of production wastewater shall be confined at all times to property owned or controlled by the Discharger, as shown in Attachment B. " C AOM FIIeiSimThluxoWul1 n51dx�OOC