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ontrol Board California Regional Water Quality C i� Central Valley Region w (@- Robert Schneider,Chair Winston H.Hickox r.) !—'r4,Davis Secretary for Sacramento Main Office (__ ",-Ggyernor EnvironmentalInternet Address:-http://www.swrch.ca.gnv/rwqcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95927-3003 Phone(916)255-3000•FAX(916)255-3015 12 June 2002 VIA FACAIMM-E CD Mr. Benjamin Hall Mr. Nick Musco Musco Olive Products, Inc. Studley Company 17950 Via Nicolo Road 17950 Via Nicolo Tracy, CA 95376 Tracy, CA 95376 INCOMPLETE REPORT OF WASTE DISCHARGE, MUSCO OLIVE PRODUCTS, TRACY, SAN JOAQUIN COUNTY Staff has reviewed the 30 April 2002 Report of Waste Discharge (RWD) prepared by Kennedy/Jenks Consultants and determined it is incomplete, as described below. In general, Musco proposes to increase its wastewater-flow rate to an unspecified amount between 800,000 and 1,000,000 gallons per day(as a yearly average). Musco does not propose to utilize any additional treatment, source control, or disposal land. In addition, Musca does not propose an effluent limit for dissolved inorganic solids in the wastewater, although the RWD implies that a value of 2,672 mg/l (as compared to the current effluent limit of 1,264 mg/1) is appropriate. When a RWD is incomplete, the Discharger is usually given additional time to submit the outstanding information. However, Musco has indicated repeatedly that it wishes the Regional Board to consider revised Waste Discharge Requirements (WDRs) at the 6 September 2002 meeting. In order to meet this time schedule, staff must prepare and circulate tentative WDRs no later than 6 July 2002. Therefore, staff will prepare tentative WDRs using the information in the RWD and our knowledge of the site. If Musco wishes to submit the outstanding information then staff will use it; - time pen-nitting, in preparation of the tentative WDRs. Due to time constraints, any information submitted after 17 June 2002 may not be incorporated into the-tb-htativ&WDRs,"_` General Concerns I Staff has serious reservations about preparing WDRs for the wastewater system as described, and believe that the current dissolved inorganic salt loading rate will impact water quality. Because Musco may need additional time to reduce its wastewater strength, staff will include a time schedule to meet effluent limits. Because the expanded system doe's not include any new Title 27 ponds, staff concludes that additional high strength wastewater such as waste lye, carbondioxidewater, and lye rinse water will be land applied. Many of these wastes should be discharged to Title 27 ponds, and the WDRs will require Musco to further evaluate its waste streams and construct additional Title 27 ponds if needed. Musco Olive Products should understand that the 114-million gallon storage pond is not constructed to Title 27 standards and therefore cannot be used to store designated waste. It is anticipated that the tentative WDRs will include effluent limitations for waste discharged to the storage pond. California Environmental Protection Agency Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at hq://www.swrcb.ca.gov/rwqcb5