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Mr. Ben Hall - 3 - 26 May 2004 Musco Family Olive Company established by Discharge Specification B.5 (a) in Waste Discharge Requirements Order No. R5-2002-0148 (WDRs). In addition, a third party arrangement to monitor nuisance odor incidents needs to be implemented, and the Pian is noncommittal on when this arrangement will be made. Treatment. The Plan describes Musco's current treatment train as consisting of"source reduction of inorganic salts followed by onsite land treatment of organic salts." It proposes to reduce salt further by decreasing the amount of chemicals used in processing olives and replacing sodium salts with potassium salts. It also proposes to substantially reduce discharge bicarbonate by additional rinsing of olives, a measure that will increase water use (and discharge flow) by 40 percent and decrease inorganic salts by 40 to 60 percent. The Plan states that necessary reductions beyond this will require "costly processing changes and/or some form of treatment," such as reverse osmosis (RO) treatment technology. To this end, -,:a=pilot unit test has-been-underway--to'evaluate RO feasibility;and-Musco expects to submitt-a report on its'---' ' Y findings in June 2004, Comment: Musco has reduced discharge salinity with source control measures, as addressed in the above comment, but as groundwater quality is still at issue, the amount has not been demonstrated as sufficient. It also has not been demonstrated yet that the LTU is effectively treating applied decomposable waste constituents to the degree necessary to preclude impacting groundwater with these constituents and their decomposition byproducts. While crops may take up some applied potassium, and potassium represents less threat to groundwater degradation due to lower mobility,potassium still could be a constituent of concern individually and it contributes to overall salt content. The projected application rate of total salt and individual constituents of salts should be the lowest achievable and must not exceed maximum levels identified in published references for ensuring optimal productivity of area crops. Similarly, the concentration of any waste constituent in leachate moving below the root zone cannot exceed the concentration of the constituent determined acceptable in groundwater by the Regional Board. Typical irrigation practices will concentrate waste constituents more than three times, and actual concentration factor for local practices must be factored into the project evaluation. Both these evaluations may consider compensating affects of freshwater applied to th sam ops. ' f The above notwithstanding, Musco's effluent quality need not be better in quality than the water supply used for irrigation i n the reuse area. Accordingly, the ualit of irrigation pp Y g Y q g water(s) currently utilized on the proposed reuse areas must be characterized. These reuse areas probably are irrigated with a combination of surface water (from Plan View's Central Valley Project allotment) and area groundwater. In addition to characterizing the quality of each supply type, the evaluation must identify the relative proportions of each supply type, as well as any seasonal difference in these proportions. Discharge salinity limitations imposed on Musco will likely be established at levels necessary to ensure degradation of uppermost groundwater from the proposed recycled water project cannot be distinguished from current irrigated farming practices.. The necessity of additional salt reduction will depend on the discharge's salt content following implementation of the