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Mr. Ben Hall • - 2 - • 17 September 2004
<br /> Musco Family Olive Company
<br /> The RWD reiterates Musco's request for replacing the TDS limit with an IDS limit. Musco states IDS is
<br /> more representative of the discharge's mineral content and a more appropriate parameter for assessment
<br /> and regulation of salinity control. Musco maintains that the TDS limit captures organic constituents that
<br /> subsequently undergo microbial degradation in the 84=mg reservoir and represent no threat to
<br /> groundwater. However, even if the TDS limit IDS of 2,047 mg/L was expressed as IDS, the IDS of the
<br /> discharge from the 84-mg reservoir exceeds this value.' Recent self-monitoring data show aeration in the
<br /> 84-mg reservoir has been effective in reducing the discharge BOD from 3,000 to around 50 mg/L.
<br /> Despite this BOD reduction, the data shows no appreciable reduction in TDS following treatment 2 It
<br /> appears,then, that nonbiodegradable volatile dissolved solids comprise a significant percentage of
<br /> discharge TDS. Additional technical information is necessary to respond to Musco's request to substitute
<br /> a TDS limit with an IDS limit. This information should describe how these solids contribute to the
<br /> discharge's overall salinity and include a technical assessment of their potential to affect groundwater
<br /> TDS concentrations.
<br /> Self-monitoring data show the discharge has dramatically increased the concentration of salt constituents
<br /> in soil. Extending the deadline for full compliance with Effluent Limitation C.1 will exacerbate a
<br /> condition of excessive IDS loading. To act on Musco's request, Musco should describe what additional
<br /> actions it will take in the short term to further reduce, at a minimum,the discharge's sodium content.
<br /> These actions should include fully automating the controls that govern the cannery floor drain sump
<br /> discharge and the discharge of storm water from the processing areas to ensure high salinity wastewater is
<br /> always diverted to the SI, improved control of the brine makeup tank flow, and other measures the RWD
<br /> identifies as pending. Additional information is also required to demonstrate Musco is maximizing its
<br /> discharge to the SI. The RWD indicates that the SI is sized to accept, on average, 30,000 gallons per day
<br /> and identifies three wastewater streams that are always discharged to the SI (i.e., boiler blowdown,
<br /> softener regeneration, floatation tank). These streams, according to Table 2 in the RWD, represent a
<br /> daily average discharge flow of only 20,090 gpd. The RWD identifies, but does not quantify, other
<br /> wastewater streams discharged to the SI (e.g., spent lye, water from washing down the tank area prior to
<br /> the onset of the rainy season). At a minimum,the RWD should present a table listing each wastewater
<br /> stream, and their respective volumes, that are discharged to the SI and, if the wastewater stream is also
<br /> discharged to land, describing what conditions trigger the discharge to the SI. Once the record contains
<br /> sufficient evidence to demonstrate Musco is doing everything reasonable in the interim to minimize the
<br /> IDS loading, staff can support recommending that the Regional Board extend the deadline.
<br /> The second requests the Regional Board extend by one year the 6 September 2004 deadline for submittal
<br /> of a technical report summarizing groundwater conditions in the discharge vicinity and characterizing
<br /> background water quality. This submittal is required to fulfill Provision G.2.j. On 2 August 2002,
<br /> Musco submitted a technical report, Background Groundwater Quality Report for Musco Family Olive
<br /> While the discharge to the 1-mg pond appears to consistently exhibit IDS concentrations below the 2,047 mg/L value
<br /> established for the TDS limit,the discharge from the 84-mg reservoir does not(due largely to the concentrating effects of
<br /> evaporation).
<br /> 2 If decomposable dissolved solids comprise a significant percentage of TDS,the 84-mg reservoir discharge should be
<br /> characterized by lower,not higher,TDS concentrations than the discharge to the 1-mg pond and the IDS component of
<br /> TDS should be substantially higher compared to the TDS value following treatment in the 84-mg reservoir, According to
<br /> Musco's June 2004 self-monitoring report,the discharge to the 1-mg pond was characterized as having 2,945 mg/L BOD;
<br /> 3,373 mg/L TDS; 1,963 mg/L IDS;and 781 mg/L sodium; and the discharge from the 84-mg reservoir was characterized
<br /> as having 51 mg/L BOD;3,791 mg/L TDS;2,198 mg/L IDS;and 939 mg/L sodium. Therefore,the IDS component of
<br /> TDS increased only from 52 to 58 percent following treatment in the 84-mg reservoir, and the TDS of the 84-mg reservoir
<br /> was actually higher than the discharge to the 1-mg pond.
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