SITE INFORMATION AND CORRESPONDENCE

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Bert E. Van Voris -22 - • 17 September 2004 Supervising Engineer to levels that do not pose a threat to water quality. These measures may include the establishment of permanent crops with deep rooting depths (e.g., poplars)that should be irrigated—at least initially—with high quality water such as the facility's raw source supply. Pond Silt. The RWD states that silt dredged annually from the pond is"spread on an onsite field. ,35 It does not characterize the quality of the silt or identify the volume discharged annually. Comment: Describing that pond silt is "spread directly on onsite soils"36 inadequately characterizes this discharge. The RWD should identify the volume of pond silt discharged annually; describe the manner in which it is dredged from the pond and measures implemented to preclude the release of leachate from dredged silt to the surface water drainage adjacent to the pond; characterize the quality of pond silt for, at a minimum, salinity, total organic content, sodium, chloride, and nitrogen; thoroughly describe the manner in which it had been discharged historically and will be discharged in the future; and estimate the loadings of waste constituents to land resulting from the discharge (past, current, and future). Monitoring and Proposed Limitations The RWD describes a monitoring and reporting program for onsite discharge, and the RWR describes a similar program for offsite recycling. The RWD indicates that regulation of onsite application be through BOD, nitrogen, and IDS mass loadings, and that hydraulic applications will be limited by site characteristics and climatic conditions. The RWD requests limitations be expressed in terms of IDS and BOD; estimates the IDS of recycled water as ranging from 900 to 1,200 mg/L; and identifies the following target levels as representing ambient groundwater quality: TDS (2,100 mg/L), sodium(720 mg/L), and chloride (600 mg/L). Comment: To fully reflect BPTC, all wastewater discharged to the reservoir should be treated to at least secondary standards. As explained in the 26 May 2004 Regional Board letter, secondary treatment would reduce the discharge's organic solids to negligible amounts compared to its inorganic solids concentration. The RWD bases the target salinity treatment levels on insufficient data (three offsite wells). See page 8 for comments regarding Musco's target salinity limits. The RWD requests Musco be allowed to discharge olive leaves and that maximum nitrogen loadings be increased to 6801bs/year/acre(from wastewater and presumably also from olive leaves), and attempts to justify this request by indicating there should be substantial nitrogen losses due to volatilization and denitrification. Comment: The poor performance of seed germination and crop cover argues for nitrogen loadings to be decreased, not increased as proposed. The appropriateness for the proposed rate of 680 lbs/year/acre is not substantiated by evidence in the record. The olive leaf discharge conducted to date has overloaded the soils with nitrogen and the RWD provides no information regarding proposed nitrogen loading rates from this discharge.