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t California F&ional Water Quality Corol Board <br /> _ Central Valley Region <br /> Katherine Hart, Chair Arnold <br /> Linda Adams 11020 Sun Center Drive#200, Rancho Cordova,California 95670-6114 Schwarzenegger <br /> Phone(916)464-3291 •FAX(916)464-4645 Governor <br /> Secretary for http:/Iwww.waterboards.ca.gov/centralvalley <br /> Environmental u ECEyED <br /> Protection IIIJJ^((f1 /(" � <br /> 19 May 2010 MAr 2 1 Ulu C <br /> ENVIROAIENT HEALTH <br /> Mr. Ben Hall PERMIT/SERVICES <br /> Musco Family Olive Company <br /> 17950 Via Nicolo <br /> Tracy, CA 95376 <br /> INCOMPLETE REPORT, PRELIMINARY ORKPLAN FOR EVALUATION OF <br /> IN GROUNDWATER, MUSCO FAMILY OLIVE COMPANY, SAN JOAQUIN COUNTROGEN <br /> Staff has reviewed the 7 May 2010 Preliminary Workplan for Evaluation of Nitrogen in <br /> Groundwater(Workplan), prepared by Kennedy/Jenks Consultants for the Musco Family <br /> Olive Company facility in Tracy, San Joaquin County and determined it is incomplete. The <br /> Workplan was required by Waste Discharge Requirements (WDRs) Order No. R5-2010- <br /> 0025, Provision G.1.b. The results of the investigation are intended to address the <br /> requirements of Provision G.1 .d for a Supplemental Evaluation of Nitrogen in Groundwater <br /> and BPTC Measures Report. <br /> We understand the Workplan is preliminary and that additional work will be performed, <br /> however, the Workplan does not adequately address the following items. At a minimum, the <br /> following items shall be addressed: <br /> 1. The transmittal letter addressed to Mr. Ken Landau mentions "Musco's plans for <br /> evaluating several potential explanations for elevated concentrations of nitrogen <br /> encountered in several of Musco's groundwater monitoring wells." Presumably, the <br /> Workplan was designed to investigate the potential causes, but no descriptions of what <br /> the causes might be are provided in the Workplan. The potential causes should be <br /> discussed so the Workplan approach can be considered with that information in mind. <br /> 2. Section 1.1 describes the site background and states, "The history of the subsurface <br /> characterization activities at the Site and the resulting understand(ing) of local geology, <br /> hydrogeology and groundwater quality have been presented by Musco in prior <br /> documents and are not repeated in this Work Plan." Due to staff assignment changes at <br /> the Central Valley Regional Water Quality Control Board (Central Valley Water Board), it <br /> would be very helpful to list the documents relied upon. Please add the list of reports <br /> related to groundwater quality investigations in the References section of the Workplan. <br /> 3. Section 1.2 describes evaluating the potential sources of elevated concentrations of <br /> nitrate in several of 32 groundwater monitoring wells. Please note that WDRs <br /> Provision G.1 .b requires investigation of total Kjeldahl nitrogen, ammonia nitrogen, and <br /> nitrate nitrogen. The text should be clarified to accurately describe the goals of the <br /> investigation. <br /> 4. The second paragraph of Section 1.2 refers to Figure 3. Figure 3 was not provided and <br /> it is not listed in the report's table of contents. <br /> California Environmental Protection Agency <br /> cYecycled Paper <br />