SITE INFORMATION AND CORRESPONDENCE

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AGENCY NAME: Musco Family Olive Company and the Studley Company Page 3 FACILITY NAME: Wastewater Treatment &Land Disposal Facility SECTION D—COMPLIANCE ASSESSMENT 1. The Discharger is in threatened violation of Prohibition A.1. See comment 9, Section D for more details. 2. The Discharger is in violation of Discharge Specifications B.S.a, c and B.11. See comment 9, Section D for more details. 3. The Discharger is in threatened violation of Land Application Area Specifications D.2 and D.14. See comment 9, Section D for more details. 4. Regional Board staff need more groundwater data to determine whether the Discharger is in violation of Groundwater Limitation F. See comment 9, Section D for more details. 5. The Discharger is in threatened violation of Solids Disposal E.3. See comment 9, Section D for more details. 6, 7, 8. A detailed summary of the Discharger's compliance with time schedules established by the WDRs, CAO, and TSO will be sent under separate cover. 9. Other: Inspection Narrative Summary. Ms. Jo Anne Kipps and I inspected the Musco Family Olive Company's facility (hereafter facility) in Tracy, California on 12 March 2003. It was a sunny day with light winds from the southeast. Background. The facility processes black olives. The olives are received, stored in an acetic acid solution, cured in sodium hydroxide (lye), rinsed several times,pitted, and canned in a brine solution. The Discharger separates wastewater into waste streams that are either discharged to Title 27 ponds or to the settling pond. Floatation brine, softener regeneration, spent lye, and boiler blowdown are discharged to the Title 27 ponds. The Title 27 ponds are regulated under a separate Order and were not included in this inspection. Waste streams that are discharged to the settling pond include carbon neutralized lye rinse water and dissolved foam from the stirring of olives in acetic acid. Wastewater from the settling pond is applied to land via sprinklers at agronomic rates or, when irrigation is not possible (e.g., during rainfall events or conditions of saturated soils), discharged to the storage reservoir until the wastewater can be land applied. Current Discharge. The WDRs permit a maximum monthly average flow of 800,000 gallons per day (gpd) of wastewater and storm water from the facility to the settling pond. The Discharger measures daily wastewater flow to the settling pond,but not daily storm water flow. During our inspection, discharge flow to the settling pond was sporadic. The Discharger has improved the facility to reduce wastewater flows and recent SMRs reveal the monthly daily average flow of wastewater to the settling pond is less than 800,000 gpd. Several years ago, the Discharger reduced wastewater flows by implementing processing changes that allow for the conveyance of olive pits without the use of water. The Discharger has achieved further flow reduction by recycling the facility's cooling water to provide sanitation inside the facility instead of directly discharging it to the settling pond. Sanitary water is discharged to a septic tank and leachfield, which is currently being expanded to adequately accommodate the facility's 228 employees.