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Mr. Michael Campos, Esq, - 3 - 41 10 <br /> 3 - <br /> 10 March 2004 <br /> application system that balances the opposing effects of land treatment to produce a leachate that reflects <br /> the nominal quality of groundwater or some reasonable degradation of it that is consistent with water <br /> quality policy. In our view, this cannot be done using the current land application site and without a <br /> significant upgrade in treatment. <br /> The Conceptual Compliance Plan in Our view is the appropriate alternative to develop as it can be <br /> successful, and it is a matter of determining what it will take. We are in the process of preparing formal <br /> comment. As staff mentioned on 27 January, "recycled water" used in the manner described in the <br /> Conceptual Compliance Plan requires a quality suitable for direct beneficial use, which commonly means <br /> secondary treatment of conventional pollutants. The effluent from secondary treatment is typically <br /> characterized by concentrations of BOD and total suspended solids not exceeding 40 mg/L each, and <br /> more commonly 30 mg/L each. <br /> Given that Musco hopes to continue on-site application for up to five years if it follows the Conceptual <br /> Compliance Plan, it should concentrate on demonstrating that the waste constituents released during this <br /> period will be (1) immobilized and either removed (periodically or at the end of the period) or closed in <br /> place consistent with Title 27, or (2) cause no greater impact to the environment than Musco is willing to <br /> risk being required to investigate and cleanup in conformance with the State Water Resources Control <br /> Board's Resolution 92-49, "Policies and Procedures for Investigation and Cleanup and Abatement of <br /> Discharges under Water Code Section 13304." <br /> As not to foreclose an option that may still be made viable but is unforeseen by this staff, we remain open <br /> to discuss your ideas on a revised proposal p <br /> p p for an LTU demonstration, or on how you anticipate you will <br /> address the interim discharge. <br /> If you have any questions regarding this matter, please contact Ms. Jo Anne Kipps at (559) 445-5035. <br /> B R V ORIS <br /> Supervi ng Engineer <br /> RCE No. 24105 <br /> Enclosure: Findings 72 through 74 of WDRs Order No. R5-2002-0148 <br /> cc w/o encl: Ms. Teresa Geimer, California Department of Water Resources, Sacramento <br /> Ms. Charyce Taylor, California Department of Water Resources, Fresno <br /> Mr. Mike Huggins, San Joaquin County Environmental Health Department, Stockto <br /> Mr. David Irey, Esq., San Joaquin County District Attorney, Stockton <br /> Mr. Bill Jennings,DeltaKeeper, 3536 Rainer Avenue, Stockton, CA, 95204 <br /> Mr. Ben Hall, Musco Family Olive Company, Tracy <br /> Mr. Nick Musco, Studley Company, Tracy <br /> Mr. Joseph Drago, Kennedy/Jenks Consultants, San Francisco <br /> Mr. Paul Harpainter, Tracy <br /> V:\Municipal\Projects\Outgoing.2004\work plan related\ams Musco LTU AssimCap.doc <br /> N15/E/MUSCO FAMILY OLIVE COMPANY/W WT&LAND DISPOSAL FACILITY/511392059002 <br />