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Bert E. Van Voris - 3 - 17 September 2004 <br /> Supervising Engineer <br /> However, in review of the RWD, I am not convinced that Musco has implemented all <br /> feasible salinity management controls to reduce both IDS and sodium even if full <br /> compliance with Effluent Limitation C.1 itself was not achievable. Additional <br /> information is required to demonstrate Musco is maximizing its discharge to the SI. Staff <br /> will favorably consider recommending an extension if Musco describes what additional <br /> actions it will take in the short tern to further reduce, at a minimum,the discharge's <br /> sodium content. These actions should include providing information that demonstrates <br /> Musco is maximizing its discharge of high salinity wastewater streams to the SI. Other <br /> actions 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 <br /> salinity wastewater is always diverted to the SI, improved control of the brine makeup <br /> tank flow, and other measures the RWD identifies as pending. If any of these are not <br /> implemented, Musco should provide documentation why they are not feasible. Also, <br /> while not immediately germane to this request,the RWD lacks sufficient information <br /> (technical and financial)to justify the reasonableness of a 3-to 5-year period for full <br /> offsite reuse. <br /> Request 2. Extend by one year the 6 September 2004 deadline for submittal of a technical report <br /> summarizing groundwater conditions in the discharge vicinity and characterizing background water quality. <br /> Comment: I originally interpreted this request as pertaining to the 6 September 2004 <br /> deadline stipulated by Provision G.20) of the WDRs. On 2 August 2004, Musco <br /> submitted the subject technical report, which was prepared and certified by Joseph Drago <br /> of Kennedy/Jenks Consultants and Anne P. Cavazos (RG No 6425). Regional Board staff <br /> is currently reviewing the report for adequacy. Michael Campos, Musco's attorney, <br /> clarified that this request pertains to obtaining additional information to reliably <br /> characterize groundwater in the area wastewater will be recycled offsite. Additional time <br /> to complete off-site characterization is reasonable, but need not be considered as a <br /> component of Provision G.2.j. <br /> Form 200 -RWD <br /> Section I, Facility Information, identifies Musco, a corporation, as the facility owner and operator and <br /> Studley Company, a partnership, as the owner of the land containing the discharge. Section II, Type of <br /> Discharge, identifies the proposed discharge as "Wastewater Reclamation." Section III, Location of <br /> Facility, identifies the Assessor's Parcel Numbers (APNs)for two parcels occupied by the facility and <br /> three parcels comprising the wastewater storage and disposal areas. Section IV, Reason for Filing, <br /> identifies the Regional Water Quality Control Board as the lead agency under the California <br /> Environmental Quality Act (CEQA) and indicates a public agency has determined the project is exempt <br /> from CEQA. The explanation for the exemption references Title 14, California Code of Regulations, <br /> Sections 15162 and 15301, and Finding 95 of Musco's current waste discharge requirements (Order No. <br /> R5-2002-0148). Section V indicates a Notice of Determination has been filed under CEQA. The RWD <br /> does not include a copy of the CEQA document, a Negative Declaration that the Regional Board <br /> approved on 28 February 1997. <br /> Comment: While the Form 200 does not have a specific place to note the state of <br /> incorporation, the RWD should identify (either in the technical document or on the <br />