SITE INFORMATION AND CORRESPONDENCE

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AGENCY NAME: Musco Family Olive Company and the Studley Company Page 6 FACILITY NAME: Wastewater Treatment &Land Disposal Facility observed water seeping downgradient from the outfall structure. Field sampling of this water determined it had an EC of 3,200 µmhos/cm and a pH of 8.18. The EC is similar to wastewater in the storage reservoir and over 1,000 µmhos/cm greater than the EC of groundwater surfacing in the seep upgradient of the storage reservoir. The elevated EC of water surfacing in the vicinity of the outfall structure suggests that wastewater is seeping from the storage reservoir and discharging to the natural drainage channel that traverses and eventually exits Mucso's property. Additional monitoring of this water for key constituents is necessary to confirm the extent to which wastewater seepage from the storage reservoir is impacting the quality of surface water downgradient of the dam. Land Application Areas. Land Application Area Specification D.2 requires the Discharger grow crops on all application areas and that cropping activities be sufficient to take up all nitrogen applied. We did not inspect all of the land application areas, but the fields that we did inspect showed varying levels of crop growth (Photos 22, 23). Compared to vegetation growth in surrounding rangeland (Photo 24), the crop growth in land application areas appeared sparse and stunted. Mr. Benjamin Hall said their agronomic advisor, Mr. Nat Dellavalle, told him the poor crop growth might be partly due to the soil, which is clayey and has poor infiltration characteristics. To improve plant growth, the Discharger constructed 30" wide raised beds in the fields, is installing moisture probes to monitor moisture movement. The Discharger also installed rain gauges to monitor rain depth. Mr. Dennis Leikam monitors the application areas. The Discharger contracts Mr. Tom Pereira, a local farmer, to keep the sprinklers operational. The sprinklers run in 15-minute intervals and are manually repositioned when necessary. Land Application Area Specification D.2 also requires the Discharger select crops based on nutrient uptake capacity, tolerance to high soil moisture conditions, and consumptive use of water and irrigation requirements. The Discharger is experimenting with different crop and claims to have been successful with rye and sudan,but not as successful with barley. The Discharger planted the 4.9-acre field called "Spur North" with alfalfa and is preparing the field called "Evap West" for spring planting with alfalfa. Land Application Area Specification D.14 requires the Discharger manage and minimize erosion and runoff from the land application areas. We observed one tail water area with a significant amount of silt (Photo 25), indicating improvements are necessary to minimize erosion and runoff. We informed Mr. Hall that we continue to receive odor complaints from Mr. Paul Harpainter, the facility's neighbor to the east (Photo 23). Mr. Harpainter states he detects objectionable odors during periods of wastewater application. When asked whether or not the irrigation pipelines were flushed with fresh water after each application period, Mr. Hall indicated the irrigation delivery system drains by gravity flow. However, persistent odor conditions during land application may be partly due to insufficient drainage of the irrigation delivery system at the end of each application. Because several days may pass between wastewater applications, it is possible that wastewater applied at the onset of irrigation may be dominated by septic wastewater. The Discharger was not irrigating on the day of our inspection due to a forecasted storm event, so we were unable to confirm whether strong odors occur during irrigation. Solids Disposal E.3 requires any storage of process wastewater solids or sludge (including olive pits) on the Discharger's property be temporary, controlled, and contained in a manner that minimizes leachate formation and precludes infiltration of waste constituents to the soils. Olive leaves and solids from the ponds are spread on small portions of the land application area, all other solid waste streams are disposed of off-site. The Discharger is currently discharging leaves to a relatively level 5-acre portion of the field called "South Ridge East." The Discharger distributes the leaves in concentrated areas and we detected the vegetation in these areas to appear healthy and thick. Mr. Hall stated that the Discharger removes