SITE INFORMATION AND CORRESPONDENCE

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AGENCY NAME: Musco Family Olive Company and the Studley Company Page 4 FACILITY NAME: Wastewater Treatment &Land Disposal Facility Self-Monitoring Report Review. Discharger self-monitoring reports (SMRs) are timely, but continue to be incomplete. The Monitoring and Reporting Program(MRP)requires daily wastewater pond monitoring, but the Discharger only monitors on weekdays. The MRP requires daily flow measurements and BODS loading rate calculations of all land application areas receiving wastewater,but the Discharger does not measure the flow or calculate the BODS loading of fields that irrigate wastewater without using sprinklers. The MRP requires a daily estimate of the storm water flow into the storage reservoir based on the intensity of the storm and the drainage basin, but the Discharger only provides a monthly estimate of the storm water flow based on the change in surface elevation of the settling pond. The MRP requires the Discharger note and explain all violations, but the Discharger's summary does not include this information. Housekeeping Deficiencies. The Discharger's operation and maintenance of many areas within the facility exposed to rainfall was unsatisfactory. General housekeeping was poor in a manner that could degrade the quality of storm water runoff and of groundwater quality the facility. One of the sumps had several cracks in its concrete floor (Photo 1). When asked when the sump was last inspected for integrity, Mr. Hall could not say when. In the tank farm area, we noted a broken floor grate (Photo 2), pallets loaded with deteriorated bags of chemicals (Photos 3, 4), a clogged gutter grate (Photo 5), and multiples spills and leaks of storage solution (mostly acetic acid) from storage vessels and piping in the tank farms (Photos 6, 7). When asked about the leaks, Mr. Benjamin Hall replies, "You cannot stop the drips." In the facility's solid waste and materials storage area, we saw numerous spilled perforated cans that were draining brine canning solution onto the pavement (Photos 8, 9). Mr. Hall indicated the canning brine has a total dissolved solids concentration of about 10,000 mg/L. Also in the solid waste and materials storage area, we observed stained soil evidencing spill(s) from a diesel storage and filling station (Photo 10). Near the diesel filling station, we noted open and nearly full containers of what appeared to be spent motor oil (Photo 11). Mr. Hall said Musco had plans for sheltering chemical and petroleum storage areas from rain, but will not implement the plans for another two months or so. Water observed in the olive receiving area (Photos 12, 13) may be wastewater, storm water, or a combination of both. The above examples of poor housekeeping constitute a violation of Discharge Specification B.11, which requires the Discharger operate all systems and equipment to maximize treatment of wastewater and optimize the quality of the discharge. Onsite disposal of canning brine from damaged cans, if it is to occur at all, should be the Title 27 ponds. Wastewater Impoundments. Discharge Specifications B.S.a and c require the wastewater from 1 to 2 feet below the surface of the settling pond and the storage reservoir maintain a dissolved oxygen (DO) concentration greater than 2 mg/L and a pH between 7.5 and 8.5. Effluent Limitation C.1 establishes the following concentration limitations (in mg/L) for wastewater discharged to the settling pond: TDS 2,047, Sodium 597, and Chloride 601. The wastewater's chloride concentration exceeded this limit twice in December 2002. Recent SMRs (December 2002 and January 2003) reveal impounded wastewater consistently has a DO concentration below 2.0 mg/L, occasionally has a dissolved sulfide concentration greater than 0.1 mg/L, and frequently has a pH less than 7.5. We detected slight odors in the settling pond vicinity. A field measurement of settling pond wastewater taken at 2:43 pm revealed a DO concentration of 0.42 mg/L, an electrical conductivity (EC) of 2800 µmhos/cm and a pH of 6.75. Mr. Hall indicated an additional aerator for the 1-million gallon settling pond and ten 25-horsepower aerators for the 84-million gallon storage reservoir were on order. We observed the surface of wastewater in the settling pond to have a layer of oily scum (Photo 14), which is likely due to the presence of olive oil in the wastewater. The settling pond is unlined has steep