SITE INFORMATION AND CORRESPONDENCE

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WASTE DISCHARGE REQUIREMENTS ORDER NO.R5-2002-0148 11- MUSCO FAMILY OLIVE COMPANY AND THE STUDLEY COMPANY WASTEWATER TREATMENT AND LAND DISPOSAL FACILITY SAN JOAQUIN COUNTY Musco's onsite production well is most appropriate to use as interim background water quality. The Discharger is required to further investigate the shallow groundwater at its site and to propose final background groundwater concentrations within two years. During this period, the Discharger is also required to reduce the TDS and sodium concentrations in its effluent, as it is anticipated that final background groundwater concentrations will be at least as stringent as the interim concentrations. SITE SPECIFIC CONDITIONS 49. Local land use consists of industrial, residential, and agricultural operations. The site is located on an alluvial fan that generally slopes to the northeast. Topography varies from steep to nearly level. 50. The land application areas are located outside the 100-year flood zone. 51. The average annual total precipitation for this area of San Joaquin County is 11.3 inches. The 100-year annual total precipitation for this area is 29.7 inches. The peak monthly 100-year precipitation of 6.4 inches occurs in January. 52. Surface water drainage from the facility is to the Sacramento San Joaquin Delta. 53. Shallow soil samples were collected in the land application areas in November 1999 and April 2001 as part of the 6 April 2001 Soil Salinity Assessment required by C&A Order No. 5-00-717. The samples were collected to evaluate the wastewater application impact to soil quality. Analysis indicted that 22-percent of samples collected in the Field 55 East and Field 55 West(a total of 55 acres)may be impacted by the wastewater application and 28-percent of the samples collected in Field 95 (95 acres)may be impacted. The report stated that the high concentration of sodium in the wastewater has the potential to reduce the already low permeability of the soil. SPECIAL CONSIDERATIONS FOR FOOD PROCESSING WASTE 54. Excessive application of food processing wastewater to land application areas can create objectionable odors, soil conditions that are harmful to crops, and degradation of underlying groundwater by overloading the shallow soil profile and causing constituents of concern(organic carbon,nitrate, dissolved solids, and metals) to percolate below the root zone. 55. According to Pollution Abatement in the Fruit and Vegetable Industry, published by the United States Environmental Protection Agency(US EPA Publication No. 625/3-77-0007) (hereafter Pollution Abatement), in applying food-processing wastewater to land for biological treatment, the loading of BODS should not exceed 100 lbs/acre-day(average) to prevent development of nuisance odor conditions. 56. Acidic soil conditions can be detrimental to land treatment system function, and may also cause groundwater degradation. If the buffering capacity of the soil is exceeded and soil pH decreases below 5,naturally occurring metals (including iron and manganese)may dissolve and degrade underlying groundwater. Pollution Abatement recommends that water applied to crops have a pH