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09/22/2002 12:50 FAX 209 948 0621 %LEINFELDER 004 California Regional Water Quality Control Board Central Valley Region 9Winston H.Hickaz Robert Schneider,Chair Secretaryfor Gray Davis Sacramento Main Ofnee Governor EnvironmentalSacramento Address: http://wwu.swrcb,ca.gov/rwgcb5 Protection 3443 Routier Read,Suite A,Saeramenro,Califom is 9SM-3003 Phonc(916)255.3000•FAx(916)255-3015 TO Timuthy R, O'Brien FROM: Kim A. Schwab Assoc. Engineering Geologist Assoc. Engineering Geologist Non-Chapter 15 Discharge to Land Waste Discharge to Land DATE: I March 2002 SIGNATURE: �Q1� j�� SUBJECT: GROUNDWATER MONITORING WORKPLAN,MONITORING WELL INSTALLATION, SAMPLING AND REPORT,MUSCO OLIVE PRODUCTS, INC AND THE STUDLEY COMPANY, SAN JOAQUIN COUNTY We have reviewed the subject document dated 20 February 2002, as prepared by Kleinfelder, Inc. The Workplan was partially prepared to address the Board's notice of violation letter dated 2 February 2002 with regards to the Class II Surface Impoundments regulated under Waste Discharge Requirements (WDRs) Order No. 97-075 and Title 27, California Code of Regulations (Title 27), Division 2, Subdivision 1. We are concerned that the current groundwater monitoring system has not yielded enough water for sampling for an extended period of time, therefore we requested Musco provide additional groundwater monitoring pursuant to Title 27, §20415(b)(1)(B)Detection Monitoring Program. We request the Discharger respond to the following comments, either in an addendum or revision to the Workplan: 1. Plate 2 shows a proposed groundwater well location on the north side of the surface impoundments. It has come to my attention that the domestic wastewater system is in the vicinity of this proposed well location. Furthermore, during an inspection on 16 October 2001, irrigation of wastewater was occurring in the area immediately north of the surface impoundments. We are concerned that these two activities may have impacted groundwater quality in this area. Please provide detailed information with regards to the two above issues in order to justify this groundwater well location. If appropriate, propose an alternative location that meets the intent of the Detection Monitoring Program of Title 27. 2. Section 3.2 states that, "An experienced environmental engineer or geologist will log the soil borings." Title 27 20415(e)(2) requires all monitoring wells and all other borings (including but not limited to gas monitoring wells) drilled to satisfy the requirements of this division, be drilled by a licensed drilling contractor(or by a drilling crew under the direct supervision of the design engineer or engineering geologist), and shall be logged during drilling under the direct Supervision California Environmental Protection Agency C? Recycled Paper The energy Challenge facing Calitemis is real. Every Californian needs to take immediate action to induce energy consumption.