SITE INFORMATION AND CORRESPONDENCE

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AGENCY NAME: Musco Family Olive Company and the Studley Company Page 5 FACILITY NAME: Wastewater Treatment & Land Disposal Facility embankments with no erosion control measures (e.g., rip rap) (Photo 15). The settling pond's inlet has no splash plates (Photo 16). Wastewater is screened prior to entering the settling pond, but the screening area lacked a concrete pad beneath the screenings dumpster to catch spillage (Photo 17). The settling pond has an overflow pipe that allows wastewater to spill to a surface water drainage. Mr. Hall explained that his staff frequently inspects the level of wastewater in the settling pond and diverts wastewater to the storage reservoir when levels begin to encroach upon the level of the overflow pipe. We informed Mr. Hall that the existence of the pipe constitutes a threatened violation of Discharge Prohibition A.1. The sampling port for wastewater in the settling pond is installed on an outlet pipe to the land application irrigation system. During sample collection, wastewater not collected in sample bottles discharges directly to ground (Photo 19). No impervious surface or containment is provided to prevent waste constituents in this discharge from infiltrating into the soil. When samples are collected during periods of no irrigation, the wastewater that is sampled is that retained in the outlet piping and not the settling pond. It is unknown at this time the extent to which, if any, the current sampling port provides representative samples of settling pond discharge during prolonged periods of no irrigation. I collected samples from the settling pond's sample port, and placed the bottles in an igloo with blue ice. Samples were delivered to The Twining Laboratories Incorporated in Fresno, California at 8:12 am, 13 March 2003. The laboratories' analyses indicated the wastewater contained the following: suspended solids (960 mg/L), total Kjeldahl nitrogen (38 mg/L), and 5-day biochemical oxygen demand (BODS) (1,800 mg/L), sodium (720 mg/L), chloride (200 mg/L), and fixed dissolved solids (2,100 mg/L). We next inspected the new storage reservoir (Photo 20). We detected slight odors in the storage reservoir vicinity. Field measurements taken between 3:10 and 3:12 pm of wastewater in the storage reservoir revealed a DO concentration of 0.6 mg/L, an EC of 3,070 µmhos/cm, and a pH of 7.02. Groundwater Conditions. The quality of groundwater underlying the site is variable and background groundwater quality has not been fully established. The depth to groundwater also vanes throughout the site. Groundwater Limitation F requires the discharge, in combination with other site-derived sources, not cause underlying groundwater to contain waste constituents in concentrations statistically greater than background water quality. The WDRs require the Discharger to further investigate the shallow groundwater at its site and propose by 6 September 2004 final background groundwater concentrations. In the interim, the WDRs allow the Discharger's onsite production well to be used to provide data to characterize background water quality. The Discharger is currently in the process of expanding its groundwater monitoring well network to evaluate groundwater quality and determine possible impacts from the facility's discharge. The WDRs require the Discharger to submit 1 May 2003 a Groundwater Well Lysimeter Installation report describing the installation and development of new monitoring wells and lysimeters. The Discharger submitted an addendum letter for the Additional Hydrogeological Investigation Workplan, which is currently being reviewed. Surface Water Conditions. Upgradient from the storage reservoir, we saw a seep of emerging groundwater (Photo 21). Field sampling of this water determined it had an EC of 2,077 µmhos/cm and a pH of 7.56. Water emanating from this seep, along with any storm water runoff from the basin upgradient from the storage reservoir, is diverted around the storage reservoir in a gunite-lined bypass channel that terminates in a discharge chute that spills into the original drainage way downgradient of the dam. An outlet control vault downgradient from the toe of the dam diverts wastewater to irrigation pumps or to an outfall structure that discharges to the natural drainage downgradient of the dam. We