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Ben Hall -3- 5 November 2007 <br /> Musco Family Olive Company <br /> We also believe that flux of water through the soil column cannot be reliably measured, or the <br /> data from such measurements interpreted in a meaningful way, based on our previous <br /> experience with similar proposals. The reasons for this are not entirely clear; however, they <br /> may have to do with the transient nature of rainfall and irrigation and the fact that moisture <br /> readings are taken at much longer intervals than would be needed to resolve flux. During non- <br /> rainfall periods with regular irrigation, we would also expect the data to be difficult to interpret, <br /> even if moisture readings are taken at much shorter intervals. In addition, the Work Plan fails <br /> to propose a method to.correlate the flux determined over the study period with flux associated <br /> with design seasonal precipitation (Le., 100-year storm season and 1,000-year, 24-hour storm <br /> event). The proposed Work Plan needs to be revised to address the long-term precipitation <br /> variability, as well as the uncertainty in measurement and interpretation of data related to <br /> calculating water flux through the soil column. <br /> Finally, the proposed Work Plan neglects to describe how collected data will be used to <br /> establish the appropriate design depth of the treatment zone for each waste constituent. The <br /> Work Plan needs to be revised to include this description. <br /> The proposed Work Plan is conditionally approved, provided the concerns described above in <br /> the Conditional Approval section are addressed now, and the issues in the Additional <br /> Concerns section are addressed in a timely manner. Please submit an addendum or a revised <br /> Work Plan addressing the concerns described above by 30 November 2007. As a reminder, <br /> Task 11 of Cease and Desist Order No. R5-2007-0139 requires submittal of an Initial Status <br /> Report on Assimilative Capacity Study within 150 days of the date of this letter <br /> (i.e., 3 April 2008). <br /> If you have any questions regarding this letter, please contact Melissa Hall at (916) 464-4757. <br /> Original signed by <br /> STEVE E. ROSENBAUM <br /> Senior Engineering Geologist <br /> Land Disposal Unit <br /> Lower Sacramento River Watershed <br /> cc: Eileen Jones, United States Bureau of Reclamation, Tracy <br /> Lori Oldfather, California Department of Fish and Game, Stockton <br /> Carol Oz, California Department of Fish and Game, Rancho Cordova <br /> Joe Spano„California Department of Public Health, Stockton <br /> Charyce Hatler, California Department of Water Resources, Fresno <br /> Donna Heran, San Joaquin County Environmental Health Department, Stockton <br /> David Irey, San Joaquin County District Attorney, Stockton <br /> Rick Gilmore, Byron-Bethany Irrigation District, Byron <br /> Dennis Leikam, Musco Family Olive Company, Tracy <br /> Gary Carlton, Kennedy/Jenks, Rancho Cordova <br /> Meredith Durant, Kennedy/Jenks, San Francisco <br /> Paul Harpainter, Tracy <br />