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California Regional Water Quality C,9,pq, r r Central Valley Region nrc,pA'r SFp4 E Robert Schneider,Chair Winston H.Hickox !19 tt it t ^•• I: 00 Gray Davis Secretaryfor Fresno Branch Office Governor Environmental Internet Address: http://www.swreb.ca.gov/—mgcb5 Protection 1685 E Street Fresno,California 93706-2020 Phone(559)445-5116•FAX(559)445-5910 18 July 2003 Mr. Ben Hall Mr. Nick Musco Musco Family Olive Company Studley Company 17950 Via Nicolo 17950 Via Nicolo Tracy, CA 95376 Tracy, CA 95376 LTU ASSINIILATIVE CAPACITY STUDY EXTENSION REQUEST, MUSCO FAMILY OLIVE COMPANY, SAN JOAQUIN COUNTY By 3 July 2003 letter, Ms. Paula Hansen and Mr. Stuart Childs of Kennedy/Jenks Consultants requested on behalf of Musco Family Olive Company (Musca) an extension to 15 August 2004 for the submittal - date of the Land Treatment Unit (LTU) Assimilative Capacity Report for Musco's land application treatment system. Provision G.2.f of Waste Discharge Requirements Order No. R5-2002-0148 (WDRs) requires the submittal by 1 August 2003 of a report that contains information contained in Finding Nos. 72 through 74 of the WDRs. These findings include descriptions of performance standards applicable to Musco's LTU prescribed in Title 27, California Code of Regulations, §§20005 et seq. The letter attributes the delay to obtaining approval from Regional Board staff of Musco's proposed hydrogeological investigation work plan. This work includes the installation of pan lysimeters required by the WDRs as essential for documenting LTU performance. It describes a plan to evaluate the assimilative capacity of LTU soils by estimating the potential of the soil column to treat constituents in Musco's wastewater. The letter indicates the plan will involve the analysis of soil samples from the LTU for various physical characteristics, development of a model of water transport through soil, and use of the model to assess zones of aerobic and anaerobic conditions through the soil. The letter explains that, due to cash flow problems, Musco prefers to perform the soil sampling work for the assimilative capacity while equipment is onsite for installation of additional groundwater monitoring wells, which are required to implement the hydrogeological investigation work plan. We will transmit under separate cover comments on this work plan,but anticipate specifying 13 locations where deep (at least 250 feet deep) exploratory borings should be drilled by the mud rotary method and geophysically logged. While we appreciate Musco's desire to reduce monitoring costs, the soil sampling required as part of the LTU assimilative capacity study should be expedited to ensure sufficient information is collected over the summer months when loadings are expected to be highest. Staff cannot extend the 1 August 2003 deadline stipulated in Provision G.2.f of the WDRs as it requires Regional Board action. However, Musco's request for more time appears reasonable under the circumstances and staff will not initiate enforcement action over this delay pending Regional Board California Environmental Protection Agency 2d 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/mgcb5