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Ben Hall -3- 22 November 2006 Musco Family Olive`Company a. The minimum pond pH requirement of 7.5 was violated in the million-gallon pond on 434 occasions, out of a possible 627 monitoring events. Results for pH that did not comply with the minimum requirement of 7.5 ranged from 4.18 to 7.45. b. The minimum pond pH requirement of 7.5 was violated in the 84-million gallon pond on 199 occasions, out of a possible 630 monitoring events. Results for pH that did not comply with the minimum requirement of 7.5 ranged from 7.05 to 7.49. C. The maximum pond pH requirement of 8.5 was violated in the million-gallon pond on 21 occasions, out of a possible 598 monitoring events. Results for pH that did not comply with the maximum'requirement of 8.5 ranged from 8.55 to 11.2. k - d. -The maximum-pond pH+requirement of 8=5-was--violated-�iri-T e•84-million gallon=pond; on 29 occasions, out of a possible 630 monitoring events. Results for pH that did not comply with the maximum requirement of 8.5 ranged from 8.51 to 9.61. 5, WDRs Order No. R5-2002-0148 includes Discharge Specification B.9, which requires "[p]ond freeboard [to] never be less than two feet in any pond as measured verfically'from the wafer surface to the upper surface.of the lowest adjacent dike or levee." f a. Based on review of the DSMRs, this requirement was violated in the-million-gallon pond on nine occasions, out of a possible 626 monitoring events, as shown in the following table: Date Freeboard Date Freeboard Date Freeboard (feet) feet feet 19-Jul-2006 0.00 24-Jul-2006 0.00 27-Jul-2006 0.00 20-Jul-2006 0.00 25-Jul-2006 0.00 28-Jul-2006 0.00 21-Jul-2006 0.00 26-Jul-2006 0.00 31-Jul-2006 0.00 When Regional Water Board staff contacted Musco staff regarding the reported freeboard values.shown in the above table, Musco staff stated (via electronic mail) that Musco did "not have the hard copies of the rave"data from when-[the freeboard values] were originally recorded'; so they did not know the exact freeboard on those days. Musco staff added that they were sure that the freeboard was greater than or equal to the required two feet on those dates, because of unspecified "redundant automatic controls to prevent the pond from reaching the 2-foot freeboard mark." b. This requirement was violated in the 84-million gallon pond on 24 occasions, out of a possible 630 monitoring events, as shown in the following table: Freeboard Freeboard Freeboard Date (feet) Date (feet) Date (feet) 2-Apr-2006 1.8 10-A r-2006 1.75 18-Apr-2006 1.80 3-Apr-2006 1-75 11-A r-2006 1.75 19-Apr-2006 1-85 —4-Apr-2006 1.75 12-Apr-2006 1.75 20-Apr-2006 1.85 5-Apr-2006 1.75 13-Apr-2006 1.70 21-Apr-2006 1.93