SITE INFORMATION AND CORRESPONDENCE

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i • Mr. Ben Hall - 2 - 7 July 2003 Musco Family Olive Company The Plan indicates generally that waste olives, olive pits, olive stems, screened solids, packaging waste, used oil, solvents, and miscellaneous trash are temporarily stored in waste containers and hauled offsite to either a recycling facility or a landfill,but offers no specifics. A 21 April 2003 Notice of Violation issued as a result of a 12 March 2003 Regional Board staff inspection of the facility cited housekeeping deficiencies in the solid waste staging area (e.g., spillage of canning brine from damaged cans) that may release pollutants in storm water runoff. The Plan should address how solid waste will be stored in a manner that precludes leakage and spillage of liquid waste. The Plan indicates that 20 cubic yards of sludge from the 1-million gallon wastewater settling pond and 450 tons of olive leaves are applied annually to land application areas. According to information obtained during the 13 March inspection, past discharges of olive leaves were conducted in concentrated fashion (i.e: to the same area for several consecutive years). This practice may or may not have resulted in excessive nitrogen loading and groundwater degradation in the area. The Report does not provide information indicating whether this past disposal practice overloaded the soil profile with nitrogen or use the data in any way to address the demonstration requirement. The Plan's Appendix A consists of a copy of the 21 January 2003 Sludge Management Report(Report) requesting Regional Board authorization to apply olive leaves and pond sludge to land without increasing the WDRs nitrogen loading limits. An earlier version of the Report, dated 25 November 2002, described the proposed discharge of leaves and sludge as follows: disk leaves into about five to ten acres of fields on a rotating basis; dredge the 1-million gallon pond annually, temporarily stockpile pond silt while dredging the pond, spread wet pond silt over a 0.25- to 0.5-acre field, allow the pond silt to dry, disk the pond silt into the soil, and rotate the pond silt application area among the fields adjacent to the pond. The earlier version of the Report proposed not to discharge leaves and pond sludge to areas with available nitrogen above 175 lbs/acre, as determined by the sum of nitrate and ammonia from the annual soil sampling required in the Monitoring and Reporting Program accompanying the WDRs. Regional Board letter dated 4 December 2002 found this version of the Report unconvincing and prohibited future land application of olive leaves due to the potential for excessive nitrogen loading. Nevertheless, the Report lacks application procedures and one must assume that portions of the previous Report are intended to apply in this regard. If the previous Report still represents the proposed land application procedures for leaves and sludge, the Plan should include a description of these procedures. If not, it should specify updated application procedures. The Report includes a table characterizing the olive leaves and pond sludge. The chloride content of the pond sludge appears to be similar to the soil in many of the land application areas. The Report indicates olive leaves and pond sludge can be applied to land application areas without exceeding existing nitrogen loading limits, as the nitrogen availability to plants is less than the total nitrogen in the soil. The Report proposes to use a nitrogen factor of 40 percent of total nitrogen initially, sample the soil for ammonia and nitrate before and after each application, and use this data to evaluate the appropriateness of the nitrogen factor and the land application practice. The Plan does not specify that leaves and sludge would not be applied to soils that already contain nitrate and ammonia concentrations exceeding 175 lbs/acre or that would cause such an exceedance, as the earlier version of the Report specified. The Plan does not contain sufficient information for us to evaluate whether the proposed discharge of olive leaves and pond sludge will cause or contribute to violations of groundwater limitations.