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0 �U <br /> California Regional Water Quality Control Board > .. <br /> Central Valley Region <br /> Katherine Hart, Chair °i <br /> 11020 Sun Center Drive,#200, Rancho Cordova,California 95670-6114 <br /> Linda S.Adams (916)464-3291 • FAX(916)464-4645 Edmund G.Brown Jr. <br /> Acting Secretary for http://www.waterboards,ca.gov/centralvalley Governor <br /> vironmental Protection <br /> 18April 2011 RECEIVED <br /> APR 2 0 2011 <br /> Ben Hall ENVIRONMENTAL HEALTH <br /> Musco Family Olive Company DEPARTMENT <br /> 17950 Via Nicolo <br /> Tracy, California 95377 <br /> REVIEW OF CLASS 11 SURFACE IMPOUNDMENTS 2010 ANNUAL REPORT, MUSCO <br /> FAMILY OLIVE COMPANY, SAN JOAQUIN COUNTY <br /> Staff has reviewed the Class II Surface Impoundments 2010 Annual Report for the Musco <br /> Family Olive Company. The report was submitted in accordance with Waste Discharge <br /> Requirements Order R5-2005-0024 and meets the requirements of the Monitoring and <br /> Reporting Program (MRP) and the Standard Provisions with the following exceptions: <br /> 1. Surface water parameters were not graphed to show historical trends; <br /> 2. The leachate sample analytical results collected from the Pond B sump was not <br /> evaluated nor was the volume of sample reported; <br /> 3. The Leachate Collection Recovery System (LCRS) was not tested during 2010 and, <br /> since test data do not exist for 2010, cannot be compared to earlier tests as required <br /> under the MRP. <br /> The 2010 Annual Report is much improved from earlier reports and staff appreciates Musco's <br /> efforts to provide all required information. Please review the enclosed monitoring and <br /> reporting checklist. Staff has additional comments presented below. <br /> 1. Liner Test <br /> Leachate has been observed in the Pond A sump during May, November, and December <br /> 2010. Leachate was collected and analyzed from the Pond B south sump during November <br /> 2010. Analytical results from the leachate sample collected indicate that constituent <br /> concentrations are within historical highs and lows of chemical results for the waste water in <br /> Pond B, and thus can be characterized as leachate. The report offers no explanation for this <br /> liquid being present. The presence of the leachate suggests the upper Hypalon liner may be <br /> leaking. Pond A was constructed in 1986 and Pond B was constructed in 1991. According to <br /> a manufacturer of Hypalon liners, the maximum life span of this material is approximately 30 <br /> years. However, the type of waste water stored is also a factor in limiting life span of the liner. <br /> Staff remains concerned the leak detection devices (suction lysimeters) installed beneath the <br /> ponds in low conductivity soil may not adequately detect leaks from the liners. Coupled <br /> CIWQS VID#890744 <br /> California Environmental Protection Agency <br /> C4RecycledPaper <br />