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F14 CD la793 �yc>'u <br /> �auo a97 / ► ,7ttf <br /> California Regional Water Quality Control Board », <br /> Central Valley RegionV <br /> Robert Schneider,Chair <br /> Terry Tanuninen Fresno Branch Office Arnold Schwarzenegger <br /> Secretaryfor - Internet Address: http://www.swrcb.ca.gov/—mgcb5 Governor <br /> Environmental 1685 E Street,Fresno,California 93706-2020 Vv�D <br /> Protection Phone(559)445-5116•FAX(559)445-5910 REC D <br /> 10 March 2004 �� MAR 1 1 2004 <br /> EW <br /> Mr. Michael Campos, Esq. ajl5 PU f airy l�� tNPE MIT%SERVICES HEALTH <br /> Stoel Rives, LLP 1 q 5 Q V! )4 N l p 0 /o <br /> 770 L Street, Suite 990 <br /> Sacramento, CA 95814 <br /> LTU ASSIMILATIVE CAPACITY STUDY,MUSCO FAMILY OLIVE COMPANY, <br /> WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY, SAN JOAQUIN COUNTY <br /> In the "Conceptual Compliance Plan" of 23 February 2004 that you submitted on behalf of Musco Family <br /> Olive Company and the Studley Company (hereafter jointly referred to as Musco), you observe that you <br /> have yet to receive a response to the "Assimilative Capacity Work Plan"(Report) of 15 August 2003. As I <br /> indicated to you by telephone prior to and during our meeting on 27 January, we set aside our response to <br /> the Report when you requested a meeting to introduce an alternative conceptual compliance plan. You <br /> note that the "Conceptual Compliance Plan" assumes continued on-site land application of wastewater <br /> for up to five years, and for this reason the work proposed in the Report is still applicable. Accordingly, <br /> Regional Board staff offers the following comments on the Report. <br /> Kennedy/Jenks Consultants prepared and submitted the Report on behalf of Musco to support its request <br /> for more time to comply with Provision G.2.f of Waste Discharge Requirements (WDRs) Order No. R5- <br /> 2002-0148. Provision G.2.f specifies the information in Findings 72 through 74 (excerpt enclosed) was <br /> due August 2003. An extension request to begin developing the technical information after it was due <br /> necessitated at least a proposal with key milestones and tasks that would result in a technical report that <br /> satisfied Provision G.2.f and the Report contains the proposal. <br /> The Report proposes theoretical studies to estimate how the environment might mitigate the impacts of <br /> waste released by Musco. It defines the waste constituents as degradable organics (as measured by <br /> biochemical oxygen demand or BOD), dissolved inorganic solids, and nitrogen species (organic nitrogen, <br /> nitrate, ammonia). The Report describes tasks to quantify attenuation by"determining the treatment <br /> potential of each component of the system" and identifies the components as follows: wastewater storage <br /> reservoirs, spray field soil and crop system, vadose zone below the crop root zone, and the underlying <br /> shallow groundwater. The work includes analysis of soil and soil-pore liquid samples within the land <br /> treatment unit (LTU) for various physical characteristics, development of a model of water transport <br /> through soil, and use of the model to assess zones of aerobic and anaerobic conditions through the soil. <br /> Provision G.21 charges Musco with demonstrating that its LTU, as designed, constructed, operated, and <br /> maintained, can meet the performance standards of LTUs prescribed in Title 27, California Code of <br /> Regulations, §§20005 et seq. In brief, Musco must demonstrate that its LTU effectively maximizes the <br /> degradation, transformation, and immobilization of waste constituents in a treatment zone of no greater <br /> than five feet in depth such that the leachate exiting the treatment zone will not cause degradation of <br /> groundwater. The soil and soil-pore liquid samples taken from within the treatment zone were to provide <br /> California Environmental Protection Agency <br /> cps Recycled Paper <br />