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Mr. Benjamin Hall • 3 -• 15 May 2000 <br /> Based on the Discharger's first quarter monitoring report,the concentration of dissolved <br /> inorganic solids (DIS) exceeds limits presented in WDR No. 97-037, Discharge Specification <br /> B.6. The limits for DIS are 1264 mg/1 annual average, and 1340 mg/1 daily maximum. The <br /> average DIS concentrations reported by the Discharger in the first quarter of 2000 have all <br /> exceeded the criteria; none of the DIS concentrations were less than 2,000 mg/l. The daily <br /> maximum criterion has also been exceeded in all the reported sample events for the first quarter <br /> of 2000. The issue of excessive salt concentrations will be addressed in the revised WDRs. <br /> Discharge Specification B.7 describes application procedures the Discharger will follow as <br /> described,in the WDR Findings. Finding No. 17 states the irrigation will be limited to those <br /> times when it is not raining. Based on the self-monitoring report submitted for the first quarter of <br /> 2000, the Discharger was applying wastewater on a daily basis throughout the first quarter, <br /> despite the regular rainfall which fell during that period. <br /> The Discharger is allowing wastewater and stormwater to flow directly into a natural drainage <br /> course. These are violations of WDR No. 97-037; Prohibition A.1 states: "The discharge of <br /> process water to surface water, or any surface water drainage courses, or groundwater, is <br /> prohibited. Uncontaminated groundwater maybe evaporated or reclaimed for agricultural <br /> use. " Prohibition A.4 states, "The discharge of waste to ponded water from any source is <br /> prohibited. " Prohibition A.5 states, "The discharge of waste within 100 feet of surface waters is <br /> prohibited. " <br /> Musco Olive Products is in serious violation of its WDRs. Musco must come into compliance with the <br /> existing WDRs forthwith; by 12 June 2000 Musco shall submit information showing how it has come <br /> into compliance. <br /> We recognize that you have submitted a Report of Waste Discharge (RWD) with the request to increase <br /> your flow of wastewater from 500,000 gal/day to 850,000 gal/day. We have serious concerns about <br /> whether we can accommodate this request, as Musco cannot currently manage its waste in compliance <br /> with the existing WDRs. Staff s accompanying 15 May 2000 letter, "Notice of Incomplete Report of <br /> Waste Discharge"requires Musco Olive Products to submit technical reports to show how Musco will <br /> bring its facility into compliance with the existing WDRs and whether the request to increase the <br /> wastewater flow will impact surface or groundwater quality. <br /> If you have any questions about this notice of violation, please contact Tim O'Brien at (916) 255-3116. <br /> VYA1 V1ta--) <br /> WENDY WYELS, Chief <br /> Waste Discharge to Land Unit <br /> Lower San Joaquin River Watershed <br /> Enclosure <br /> cc: Mr. Mike Huggins, San Joaquin County Environmental Health Department, Stockton <br /> C:`Pm Filn`SnnNluuo'Hvll 01INXIp <br />