SITE INFORMATION AND CORRESPONDENCE

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Ben Hall -3- 12 May 2011 Horacio Ferriz Musco Family Olive Company furnishes a Summary of Monitoring Well Specifications (Table 1) that provides miscellaneous well information. Groundwater flow conditions beneath the ponds are difficult to interpret without current depth to water measurements recorded from all wells of interest on the same day. Collection of this data should be easily accomplished since the wells are located in a relatively small area of the facility. Future reports must include groundwater elevations from all wells of interest and provide field data sheets for each well monitored. If a well is dry, a field data sheet must be completed and included in the report for that period. Groundwater Analytical Results Section 2.3 indicates that immediately following development of the monitoring wells, groundwater samples were collected and transmitted to the laboratory under standard chain of custody control for analysis. Results of the water analyses are reportedly found in Table 2, but Table 2 is improperly labeled as Table 4. However, staff can not accept the analytical data because of the high N.T.U. value in the wells. In addition, the report does not contain the California certified laboratory report and chain of custody, field data sheets verifying the date the samples were collected and the method of purge, nor does the report contain a discussion of the analytical results. Until the wells have been redeveloped and the turbidity values have been reduced significantly, staff will not consider any chemical data reported as valid nor should the data be used for statistical analysis. Summary Staff appreciates the effort Musco has put forth to bring the Class II Surface Impoundments into compliance with Title 27 requirements. However, additional actions must be taken before the new wells can be added to the monitoring program. Therefore, by 30 June 2011 Musco must submit a Revised Well Installation Report showing that wells MW-18R, MW-20R, MW-21 R, and other wells that are part of the DMP which exceed the standard of less than 5 N.T.U. have been redeveloped. Musco shall provide field data sheets, and a copy of the laboratory chain of custody for samples submitted for analysis following redevelopment. The letter report shall include a certification from the responsible professional that the wells have been redeveloped to the best obtainable N.T.U. value and that the wells meet the intent of the DMP. If the N.T.U. value cannot meet the SW-846 or the ASTM standard, then the letter report must provide an evaluation of the well design and either propose reconstruction of the wells or justify why reconstruction will not result in lower N.T.U. values. In addition, the report must contain the missing information identified at the bottom of page 2 of this letter. We also expect that the analytical data will be removed. California Environmental Protection Agency