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0 California tegional Water Quality Control Board Central Valley Region Robert Schneider,Chair Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http:/Iw .swrcb.ca.gov/—mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 19 April 2,002 �c?•26 Mr. Benjamin Hall Mr. Nick Musco Musco Olive Products Studley Corporation 17950 Via Nicolo 17950 Via Nicolo Tracy, CA 95376 Tracy, CA 95376 INCOMPLETE REPORT, DOMESTIC WASTEWATER SYSTEM EVAL UA TION,MUSCO OLIVE PRODUCTS, TRACY, SANJOAQUIN COUNTY I have reviewed the 20 February 2002 Domestic Wastewater Disposal System Report, prepared by Neil O. Anderson&Associates (NOA) for Musco Olive Products. The report was submitted to the Regional Board on 8 March 2002 and was prepared in response to Requirement No. 7 of the California Water Code Section 13308 Time Schedule Order,which required evaluation of the current domestic wastewater system. My comments about the report the reports are listed below. Due to the number of concerns,Musco shall submit a revised report by 30 May 2002. • The report identifies four months during the year when wastewater should not be applied to the leachfield area based on local evapotranspiration. Staff agree that wastewater should not be applied to the leachfield area during this time, but is not certain that wastewater should ever be applied to the leachfield area. Dissolved solids in wastewater that is applied to land will be concentrated in soil when the water evaporates. Those constituents will likely be dissolved by rainwater and could enter the leachfield equipment. Migration of the constituents to lower zones could be speeded by the seepage pits. The revised report shall address this issue and how such migration will be prevented. Alternatively, Musco may propose a monitoring program designed to determine whether the migration of salts is occurring. • A better description of the wastewater generation is required. No discussion of the facility and the facilities available to employees is presented. For example are showers, cafeteria, food preparation areas, etc., available? • The report did not describe a site investigation to determine the site conditions, instead relying on a third parry's observation. This is not adequate for the purposes of the report. Information on the leachfield condition, plant growth, odors, and water levels in the seepage pits are basic observations and shall be described in the revised report. • The report states the domestic wastewater system was designed for 164 employees. Mr. Hall's cover letter states present employment is 228 people although during peak processing times up to 350 employees may be on-site and during those times,portable toilets are placed on site. Please provide California Environmental Protection Agency �d Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb,ca.gov/rwgcb5