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Kennedy/Jenks Consultants <br /> Engineers&Scientists <br /> 303 Second Street,Suite 300 South <br /> San Francisco,California 94107 <br /> 415-243-2150 <br /> FAX:415-896-0999 <br /> 29 September 2010 <br /> Ms. Anne Olson, PE <br /> Chief, Land Discharge Compliance and Enforcement Unit <br /> California Regional Water Quality Control Board (1 <br /> Central Valley Region (j(p /6 3 <br /> 11020 Sun Center Drive, Suite 200 <br /> Rancho Cordova, CA 95670-6114 <br /> (q <br /> Subject: Work Plan for Improved Detection Monitoring Program J 7 <br /> Musco Family Olive Company, 17950 Via Nicolo, Tracy, California <br /> K/J 020104.00 <br /> Dear Ms. Olson: / <br /> The enclosed Work Plan for Improved Detection Monitoring Program (Work Plan) is submitted <br /> by Kennedy/Jenks Consultants on behalf of the Musco Family Olive Company(Musco). The <br /> Work Plan is submitted in response to a letter from the California Regional Water Quality <br /> Control Board (RWQCB)to Musco dated 9 June 2010. The required submittal date for this Work <br /> Plan was revised to 30 September 2010 during a meeting at the RWQCB offices on <br /> 12 August 2010. <br /> During the meeting on 12 August 2010, RWQCB staff reiterated their concerns regarding the <br /> adequacy of the existing leak detection and monitoring components of Musco's Title 27 pond <br /> system. The enclosed Work Plan describes modifications proposed to improve and expand the <br /> existing detection monitoring systems in response to the RWQCB concerns. <br /> i-• <br /> It should be noted that there are three detection monitoring systems associated with the Title 27 <br /> ponds, and to date, the monitoring data indicate that leakage from the Title 27 ponds has not <br /> occurred. Moreover, the shallow groundwater zone in the vicinity of the Title 27 ponds has been <br /> dewatering over time. <br /> The two Title 27 ponds are each equipped with a double liner, with interstitial monitoring <br /> between the upper and lower liner. The leachate collection and recovery system (LCRS) is <br /> monitored on a monthly basis. Liquid has been detected in the LCRS on only three occasions <br /> since monitoring began in 2002. Each time, a sample of the liquid was collected and submitted <br /> for chemical analysis.The analytical data were not consistent with the hypothesis of a release <br /> from the Title 27 pond. <br /> The Title 27 pond system also includes a total of 37 lysimeters installed beneath the two ponds <br /> at depths of five and ten feet below ground surface. If a release were to occur, and escape the <br /> lower liner of either pond, the lysimeter system is designed to identify the presence of soil <br /> g:Bs•B�Nud�Y°nmmgBtD4.OD_rtuscmlxlgguepvts'Elle_2!_dryavdb.drc <br />