SITE INFORMATION AND CORRESPONDENCE

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Bert E. Van Voris - 20 - 17 September 2004 Supervising Engineer Comment: The RWD should characterize the quality of irrigation water historically and currently available to proposed use areas, and compare those qualities with proposed quality of discharge. In the absence of an intensive program of sulfiu is acid applications to correct sodic soil conditions, it is likely that Musco will continue to have limited success with crop growth, and the assumed return of the site to natural vegetative cover, and the erosion control it offers, is premature. Consequently, unless corrective actions are taken, the potential is high following site closure for erosion and for storm water degradation from sediments (and salt constituents). As a consequence, in order not to impact downstream water quality, storm water runoff from the LTU will have to be contained on site indefinitely and managed in a way that precludes the migration of salt and other waste constituents in the soil profile to groundwater. Regarding site closure,the RWD understates the impact to LTU soils caused by Musco's discharge. Soil monitoring data collected to date clearly indicate that Musco's discharge has resulted in massive accumulations of salinity constituents in soils to the extent that in many areas they are sodic and no longer arable. Downward mobility of salt constituents is indicated in the soil data, not perhaps on sloping areas but in low-lying areas where surface water and tailwater flows and infiltrates into the soil profile. It is necessary to deterniine the quality of soils and soil-pore liquid in these low lying areas to evaluate the extent to which salinity constituents resulting from the discharge threaten to degrade the quality of shallow groundwater that will inevitably and eventually migrate offsite. While lysimeter data is less important in light of Musco's long-term compliance plan, monitoring the quality of soil pore liquid will be an important component of site closure. My review of this submittal is beyond the scope of this memorandum. Waste Management Waste Olives, stems, and screen solids. The RWD indicates Bonzi Recycling disposes of these wastes at the San Joaquin County Landfill, and notes that occasionally"an area farmer will take the olive waste for animal feed.,'29 Elsewhere the RWD indicates that the facility produces 22 million pounds of olive pits annually that are "sold as biomass to cogeneration facilities, or pulverized and incorporated into compost."30 Comment: The RWD does not disclose that Musco has routinely disposed of waste olives on land owned by Lyons Investments in Stanislaus County. The RWD should identify the entity responsible for composting waste olives (Boni Recycling?), indicate whether the entity is conducting the composting operation under Regional Board WDRs (or waiver of WDRs), and, if not, describe the construction of the pad underlying the composting operation (e.g., natural soil, 2-feet compact clay, etc.). Olive Leaves. The RWD states that olive leaves are "spread on an onsite field."31 Elsewhere it states that prior to 2002, leaves were discharged to Park West, in 2002 to the northeast section of South Ridge, and in 2003 to a northwest section of South Ridge. The RWD describes the manner of this discharge as follows: "The olive leaves are distributed evenly over a particular section and then incorporated to an