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• -4- ADMINISTRATIVE CIVIL LIABILITY ORDER NO. MUSCO OLIVE PRODUCTS AND THE STUDLEY COMPANY SAN JOAQUIN COUNTY C. Develop and implement a hydrogeologic investigation workplan designed to assess soil and groundwater conditions beneath the discharge areas; d. Develop and implement a workplan to study the effects of the discharge on soil and crops at the discharge areas; e. Develop a plan for facility improvements designed to ensure adequate long-term wastewater storage and disposal; and f. Submit a report verifying that the facility improvements plan has been fully implemented. 17. The Discharger has submitted most of the technical reports described in Finding No. 16. Some of the reports were submitted after the dates specified in the C&A Order or were incomplete, as summarized below: No. of Days Report Title Date Due Date Submitted of Violation Winter Contingency Report 19 December 2000 19 December 2000 0 Storm Water/Surface Water Sampling Plan 19 December 2000 19 December 2000 0 Hydrogeologic Investigation Workplan 3 January 2001 3 January 2001 0 Soil Salinity Study Workplan 3 January 2001 3 January 2001 0 Hydrogeologic Investigation Report 8 April 2001 ' 14 June 2001 67 Wastewater Application(Crop Impact)Report 8 April 2001 ' 11 April 2001 3 Wastewater Facilities Improvements Plan 30 May 2001 Incomplete 240 z Wastewater Facilities Improvements Construction Report 15 November 2001 Not Submitted 71 Total Daily Violations (to 25 January 2002): 381 1 The C&A Order required submittal of the report within 90 days of workplan approval. The workplan was conditionally approved on 8 January 2001. 2 Each day that the report is incomplete is a violation equivalent to nonsubmittal of the report. 18. Since adoption of the C&A Order, the Discharger has not completely complied with the Monitoring and Reporting Program (MRP)No. 97-037. All required monitoring reports were submitted on schedule, but the reports showed that the Discharger failed to perform all of the sampling and analysis required by the MRP. These violations of MRP No. 97-037 are summarized below4 + No. of Days Monitoring Report Date Due Date Submitted Completeness of Violation t 4`h Quarter 2000 Report 30 January 2001 23 January 2001 Incomplete 360 2000 Annual Report 31 January 2001 19 January 2001 Incomplete 359 ls` Quarter 2001 Report 30 April 2001 20 April 2001 Incomplete 270 2"d Quarter 2001 Report 30 July 2001 17 July 2001 Incomplete 179 3`d Quarter 2001 Report 30 October 2001 15 October 2001 Incomplete 87 Total Daily Violations (to 25 January 2002); 1,255 1 Each day that the report is incomplete is a violation equivalent to nonsubmittal of the report.