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California Regional Water Quality Control Board <br /> vCentral Valley Region <br /> Winston H.Hickox Robert Schneider,Chair <br /> Gray Davis <br /> Secretaryfor Sacramento Main Office _ q vernor <br /> Environmental Intemet Address: http://www.swrcb.c&gov/mgcb5 wl��j ��//� <br /> Protection 3443 Routier Road,Suite&Sacramento,California 95827-3003 I1 ll `� C/ <br /> 11 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> DEC 0 6 Z00Z <br /> 4 December 2002 <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Benjamin Hall Mr.Nick Musco <br /> Musco Family Olive Company Studley Company <br /> 17950 Via Nicolo Road 17950 Via Nicolo <br /> Tracy, CA 95376 Tracy, CA 95376 <br /> INADEQUATE REPORT, SOLIDS MANAGEMENT REPORT. OLIVE LEAVES AND POND <br /> SILT,MUSCO FAMILY OLIVE COMPANY, TRACY,SAN JOA Q UIN CO UNTY <br /> I have reviewed Kennedy/Jenks Consultants' 25 November 2002 Solids Management Report, which was <br /> required by the Regional Board's 15 October 2002 Notice of Violation. The report presents a summary <br /> of laboratory analyses and an evaluation of the impact of applying the waste to land treatment units. I <br /> have the following comments on the report: <br /> • The report does not present total nitrogen data for the pond silt/sludge. Nitrate as nitrogen is <br /> presented; however, because of the anaerobic conditions in the pond and the long practice of <br /> discharging poorly screened wastewater into the pond,Regional Board staff believe organic nitrogen <br /> likely exists at elevated concentrations in the pond silt/sludge. Please analyze the samples for total <br /> nitrogen and chloride. The material should not be applied to land prior to characterization. By <br /> 21 January 2002,please submit the additional data requested for the pond silt/sludge <br /> characterization. <br /> • Analysis of the olive leaves reveals 1.41% of total nitrogen. Using the data presented in the report, <br /> this indicates a total nitrogen application of 12,690 lbs/year (approximately 63.5 lbs/ac-year over 200 <br /> acres). This is in addition to the nitrogen loading resulting from the wastewater application and may <br /> result in violations of the effluent limitations. Effluent Limitation C.2 states: <br /> "The maximum total nitrogen loading to the LTUs shall not exceed 480 lbs/ac-year, or if the <br /> crop uptake is lower, the nitrogen loading shall not exceed the agronomic rate for the crop <br /> grown. Plant available nitrogen shall be calculated as 100 percent of the total nitrogen <br /> content of the waste, unless and until the Discharge demonstrates that another proportion is <br /> technically justified, as described in the Provisions. " <br /> WDRs Finding No. 25 describes the nitrogen loading (as described in the Report of Waste <br /> Discharge) to be between 428 and 490 lbs/ac-year. Musco Family Olive Company had stated an <br /> intention to double crop the land application areas; staff s inspection of the land application areas <br /> indicates cropping has not been successful. The high loading rates resulting from the wastewater <br /> application and poor crop performance may threaten groundwater quality. Future application of <br /> California Environmental Protection Agency <br /> ea Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/mgcb5 <br />