SITE INFORMATION AND CORRESPONDENCE

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Messrs. Hall and Musco - 2 - 15 October 2002 • Discharge Specification B.5.a requires a minimum dissolved oxygen concertation of at least 2.0 mg/l in each pond. Measurements of the dissolved oxygen in the wastewater in the 1-Mgal Pond indicated concentrations from 0.32 mg/l to 0.61 mg/l. Regional Board staff and Musco employees collected the measurements. The inadequate dissolved oxygen concentration is a violation of the Discharge Specification. • Discharge Specification B.5.c requires pH of the wastewater in ponds to be between 7.5 and 8.5 standard units; measurements collected by Regional Board staff and Musco employees indicated pH concentration of 5.97 to 6.5 standard units. The low pH values are a violation of the Discharge Specification. • Discharge Specification B.6 prohibits discharge to areas not adequately maintained to prevent off- site odor nuisance, fly breeding, or mosquito breeding. The discharge of wastewater to the natural drainage and Diesel Pond is a violation of this specification. The wastewater appears to be the source of the nuisance odors, a large number of flies were present near the pond, and the quiescent conditions in the pond will be conductive to mosquito breeding. • Discharge Specification B.9 requires at least two-feet of freeboard in the ponds at all times. The freeboard at the 1-Mgal Pond was approximately one-foot. • At the area of the lye reclaim tanks there was wastewater ponded on the adjacent unpaved soil surface. From staining of the soil extending from the tanks to the ponded wastewater, it was apparent that spills had originated from the lye reclaim tanks. A sample of the wastewater was collected and pH and electrical conductivity properties were measured. The pH of the sample was 11.5. The electrical conductivity of the wastewater was beyond the range of the field instrument; the maximum range of the field instrument is 20,000 µmhos/cm. Based on the pH measurements, the waste is classified a designated waste and discharge of such waste to land is prohibited by Discharge Prohibition A.4. • In the land application areas, crop heath was poor in the 95-acre land application area. Land Application Area Specification No. D.2 requires crops to be grown in the application areas. Mr. Hall stated crops had recently been planted in much of the poor performing land areas. • Olive leaves were observed spread on the South Ridge East land treatment unit. Disposal of waste vegetation was not described in the Report of Waste Discharge and therefore is a questionable practice. The Discharger must provide additional detail on the incorporation of vegetation into the land treatment units as part of the solids management report required below. • At the 1-Mgal Pond, an excavator was removing solids from the bottom of the pond. Mr. Hall stated the solids would be spread in the application areas. This might be acceptable if the work is performed in accordance with Solids Disposal Requirement Nos. 2 and 3, which requires treatment and storage of solids and sludges to be conducted in a manner that preclude infiltration of waste constituents into soils in a mass of concentration that will violate groundwater limitations and control of leachate formation and infiltration of waste constituents into soils. The Discharger must V.\San foa uin_Nonl5 Stafr Obn=i mjmt FilatMuscoWa11101002d