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Mr. Ben Hall • - 2 - • 8 June 2003 Musco Family Olive Company floor drain, noncontact cooling water, and storm water from the olive storage and processing tank areas. The Report characterizes these wastestreams, except flume water and storm water, for TDS, fixed dissolved solids (FDSJ,'sodium, chloride, alkalinity, calcium, magnesium,phosphorous, potassium, nitrate, sulfate, boron, soluble and total biochemical oxygen demand (BOD), pH, and oil and grease. The Report identifies the three lye rinses, the spent storage solution, and the carbon dioxide water as the five wastestreams contributing the most to inorganic mass loading to land application areas. The Report indicates that Musco's existing salinity source reduction program has reduced the volume of wastewater generated and the concentration of salinity constituents in wastewater. The program features the following measures: using a closed-loop fluming system for olive transport, de-stemming, and pitting; reusing retort cooling water; reclaiming lye; neutralizing residual lye in the olives with carbon dioxide; increasing the retort cooling system operation efficiency; replacing standard hoses and nozzles with high-pressure, low-volume hoses and nozzles; installing catch pans under the conveyor belts from the flotation tank to the canning operation; switching to a foam-based cleaning system for canning area sanitation, changing from brine solution to acetic acid-based solution for olive storage; reducing the volume of storage solution per tank; installing level controls on the flotation tank; installing a conveyance system of cannery floor drain wastewater to evaporation ponds; and reducing the frequency of flotation brine change-out. She Report identifies alternatives to further reduce discharge salinity levels. It recommends Musco modify or replace the parabolic screen that separates solids from wastewater discharged to the 1-million gallon settling pond; evaluate measures to prevent the overflow of brine solution from the flotation brine makeup tank; and reduce the salinity levels in the highest salinity wastestreams by onsite treatment, such as membrane-based separation (e.g., reverse osmosis) or enhanced evaporation (e.g., a brine concentrator). The Report also recommends Musco purchase additional property to expand its land application area, soak olives in potassium hydroxide solution instead of sodium hydroxide solution, transport concentrated wastestreams to a Livermore area wastewater treatment facility (WWTF) that discharges to the San Francisco Bay, and use forced air evaporation to treat concentrated wastestreams. The Report identifies the following measures Musco considered but deemed infeasible: substituting potassium chloride solution for sodium chloride solution due to its adverse effect on product quality; using dissolved air flotation due to its poor performance with sliced and chopped olives; recycling wastewater at a power production facility due to its high water quality standards; disposing of concentrated wastestreams to a private waste treatment facility/recycling company or brine line in Southern California due to transportation logistics, constructing a dedicated brine disposal pipeline to the San Francisco Bay or discharging concentrated wastestreams to the Oakland WWTF due to costs; transporting wastewater to the Tracy WWTF due to its effluent water quality limits; and composting due to permitting issues and the excessive area of land required. Salinity Reduction Measures and Background Groundwater Quality Characterization. Order No. R5-2002-0148, Provision G.2.j, requires Musco to submit by 6 September 2004 a Background Groundwater Quality and Percolate Quality Report that, in part,proposes background groundwater limitations for the shallow and deep saturated intervals for TDS, nitrogen, sodium, and chloride. The hydrogeologic investigation required to complete the Background Groundwater Quality and Percolate Quality Report may reveal that the maximum salinity concentrations prescribed by Effluent Limitation C.1 might be excessively stringent or, conversely, not stringent enough. Mr. Campos requests on behalf of Musco that the final compliance date under the Cleanup and Abatement Order be