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Musco Olive Products - 2 - 12 June 2002 The source control section of the RWD is inadequate because it is not specific,measurable, or scheduled. Many of the source control measures the section describes have already been implemented, some as far back as 1994. While these measures are commendable, the wastewater flow rate has dramatically increased since 1994 and concentrations of dissolved inorganic solids have steadily risen. Section 4.4.1 acknowledges limited capacity of the Title 27 evaporation ponds and it is'apparent that due to limited space in the ponds, higher strength wastewater is being land applied. The RWD recommends additional source control measures be evaluated, and that each waste stream be fully characterized. Additional characterization and source control will likely be required in the tentative WDRs. Groundwater Quality The description of the wastewater disposal system does not demonstrate how the method of disposal will not impact groundwater quality and in fact, seems to rely upon leaching of dissolved solids below the root zone to allow crop growth. Dissolved solids leached below the root zone would be anticipated to degrade groundwater quality. In this case, with a projected dissolved solids application rate of 32,000 lbs/acre-year and an estimated crop uptake rate of approximately 2,800 lbs/acre-year, the RWD does not demonstrate that groundwater quality will be protected. Therefore, the tentative WDRs will provide a lower effluent limit for dissolved solids than the design value presented in the RWD. The RWD presents groundwater quality data for nearby domestic/industrial/agricultural wells. Staff recognizes that water quality is poor; however, the Basin Plan describes beneficial uses of the water. Those beneficial uses must be protected in WDRs that are adopted. The quality of the wastewater appears to be worse than any of the nearby groundwater, indicating additional treatment or source control is needed. Nuisance Odors The continuing generation of nuisance odors must be controlled. The RWD does not include an evaluation of the storage ponds' potential to generate odors. Mechanical aeration of the wastewater may be required to control odors. This issue should be addressed in the odor control report to be submitted by 28 June 2002 (per the revised Time Schedule Order) that will describe the additional steps Musco has taken to prevent nuisance odors. .� --- ——Additiarial�Quest>;-�ns_.--_d�-------�---.d- --A�=�y-•_—a--- - ......, ��,. � � � . .-� -_. In reviewing the RWD, it was noted that many of the information requirements listed in the Regional Board's 13 March 2002 Request for a Report of Waste Discharge were not adequately addressed in the submittal and therefore are repeated in this letter. The following information should be submitted to complete the RWD: 1) Provide a description of the facility including,products produced, number of olive storage tanks, olive processing tanks, tons of olives processed, and number of employees. Please address the apparent inconsistency on capacity in Section 2.1.2 which states Musco's olive storage capacity is 47,000 tons but processed 50,000 tons. Previous information submitted to the Regional Board indicated Musco Olive Products processed 55,000 tons last year and has a maximum capacity of approximately 60,000 tons. How will the 40-percent increase in wastewater flow change the stated numbers? V,\San_JoaquinNOnInStaft50biimTWusco_June 2002\Hall 061202.do