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0 <br /> Bert E. Van Voris - 6 - 25 February 2005 <br /> Supervising Engineer <br /> measures that will be taken to preclude the generation of odor or vector conditions that <br /> may be perceivable beyond Musco's property at levels that create or threaten to create <br /> nuisance conditions. <br /> The RWD still does not(a) identify the TDS concentration of wastewater following acid <br /> treatment; (b) explain how it would be possible to sustain crop growth, let alone <br /> germinate planted seeds,when applying wastewater containing elevated sodium; and <br /> (c) evaluate the potential impact to groundwater quality due to the application of sulfuric <br /> acid to restore the soil properties damaged by Musco's sustained discharge. The benefit <br /> of restoring soils within the root zone must be balanced against potential impacts from <br /> the leaching of excessive sodium and other constituents deeper into the soil profile and <br /> potentially to groundwater. <br /> The RWD did not propose to measure the tonnage of crops harvested from application <br /> fields and perform plant tissue analyses to identify the amount of nitrogen (and other <br /> waste constituents) that are actually removed by the crops, and this should be considered <br /> as a waste discharge requirement. <br /> The RWD does not contain(a) a history of the land application(i.e., identify for each <br /> field when discharge was initiated and, if applicable, when it was used to compost olive <br /> leaves or used as a disposal site for pond silt); (b) a tabulation of the accumulated annual <br /> loadings (lbs/acre-year) of IDS, sodium, and chloride, to each land application held since <br /> discharge was initiated;or(c)the estimated additional loadings (lbs/acre-year) of IDS, <br /> sodium, and chloride to each field that will result from continued discharge. It is <br /> appropriate to quantify this information as the accumulated salt represents an ongoing <br /> threat to groundwater that must be evaluated as part of long-tern use or for closure. A <br /> condition to this effect should be part of the WDRs. <br /> Solids Mana eg ment <br /> Musco proposes to temporarily stockpile leaves in windrows during the fresh olive processing season <br /> and apply these leaves to the land application area after harvest and before winter rains. Musco proposes <br /> to apply the leaves to about 60 acres each year and to rotate leaf application sequentially over all land <br /> application fields from year to year. The total nitrogen loading to the land application fields will be <br /> 315 lb/acre/yr when leaves are not applied, and 480 lbs/acre/yr when leaves are applied, using a <br /> wastewater total nitrogen concentration of 40 mg/L and an estimated wastewater irrigation rate of <br /> 35 inches per year. <br /> Comment: The RWD should have identified the areas to which Musco proposes to apply <br /> organic soil amendments such as olive leaves, showed calculations for the nitrogen <br /> loading, as well as demonstrated by crop selection that the nitrogen loading will not <br /> exceed the anticipated crop uptake. The RWD should have provided details on the <br /> construction of the area(s) Musco proposes to use to stockpile leaves. The RWD should <br /> have characterized the quality of sediment periodically removed from the 1-million gallon <br /> settling pond and discharged to the land application fields, and evaluated the extent to <br /> which this discharge may unreasonably degrade groundwater. The WDRs must include <br /> appropriate conditions for these generally described activities. <br />