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AM • California Regional Water Quality Control Board Central Valley Region v Robert Schneider,Chair + Terry Tamminen Fresno Branch Office Arnold Schwarzenegger Secretaryfor Internet Address: http://wvvw.swrcb.ca.gov/-mgcb5 Governor Environmental 1685 E Street,Fresno,California 93706-2020 - Protection Phone(559)445-5116•FAX(559)445.5910 n �It \'i 1=� 19 December 2003 pEN 2 3 2003 ENZ NEA�(N ONS S Mr. Ben Hall ENPENMIT�SERVIGE Musco Family Olive Company 17950 Via Nicolo Tracy, CA 95376 SWRCB INVOICE 0304947,MUSCO FAMILY OLIVE COMPANY,WWT & LAND DISPOSAL FACILITY, SAN JOAQUIN COUNTY By copy of your 5 December letter to the Accounting Office of the State Board,you request that Musco's discharge to land be reclassified as a category 2 threat to water quality and of category C complexity (i.e., 2C). The discharge's threat to water quality and complexity is currently classified as 1B. Your letter indicates Musco is paying the invoice in full ($26,160) based on the current classification, but requests a reclassification from this Regional Board and then a refund from the State Board for overpayment of the annual fee based on an expected reclassification. I have looked into the matter of appropriate discharge classification in response to your letter and determined it to be 1A. Threat to water quality and complexity of the discharge is assigned in accordance with established general definitions in Title 23, California Code of Regulations (CCR), § 2200. Threat to water quality is a relative categorization of the discharge's potential effect upon the surface or ground water quality and the beneficial uses of those waters (e.g., drinking water supply). Category 1 includes those discharges that could cause long-tern loss of a beneficial use. Category 2 includes those discharges that could impair the designated beneficial uses, cause a nuisance or short-term violations of water quality objectives, violate secondary drinking water standards, etc. The designated beneficial uses of underlying groundwater in the discharge area include domestic and municipal supply and agricultural supply. The underlying groundwater in the discharge area with respect to salinity constituents is not of high quality. Background groundwater quality has yet to be fully characterized, but clearly some aquifer zones meet secondary drinking water standards and, most importantly, these zones do not qualify for exception as a potential drinking water supply under terms of State Board Resolution 88-63. Some groundwater (e.g., MW-1, MW-4, MW-8, MW-15, and W2) meets the criteria of Class II irrigation water'. Musco's wastewater discharge quality is considerably worse than the salinity in these better quality zones for most waste constituents that are monitored, and exceeds the TDS criteria for Class II irrigation water (even when measured as inorganic TDS). The discharge is further concentrated during storage and the application process. Data suggests degradation of groundwater is already occurring. Degradation from salinity is typically an impact of long-term duration. Therefore, Musco's discharge has the potential to cause the long-term loss of the beneficial use of Class II irrigation water is classified as having 700—2,000 mg/L TDS; 1,000—3,000 µmhos/cm EC; 175—350 mg/L chloride,60—75 percent base TDS constituents as sodium, and 0.5—2 mg/L boron. California Environmental Protection Agency �a Recycled Paper