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Kennedy/Jenlcs Consultants Ms. Anne Olson California Regional Water Quality Control Board 29 September 2010 Page 2 moisture and, if sufficient moisture is collected in a lysimeter, to facilitate collection of a sample. The lysimeter data indicate that soil beneath the ponds is dry, and that leakage from the Title 27 ponds has not occurred. In the immediate vicinity of the Title 27 ponds, seven groundwater monitoring wells have been installed in the shallow aquifer zone, and four groundwater monitoring wells have been installed in the underlying, intermediate zone. Earlier in the facility's history, the shallow aquifer zone was identified as "first-encountered groundwater". However, the shallow aquifer zone has dewatered, and each of these seven monitoring wells is dry. Three shallow zone monitoring wells installed in 2006 at the request of the RWQCB never yielded water. Two of the four intermediate zone wells no longer yield sufficient water to sample, and water levels in the other two intermediate zone monitoring wells are declining with time. Groundwater levels in the vicinity of the Title 27 ponds are declining over time, and the data do not indicate a release from these ponds. Musco maintains and monitors the systems necessary to detect a potential release from the Title 27 ponds. Monitoring of the systems is performed in accordance with RWQCB requirements. Both individually, and in the aggregate, the three sets of monitoring data indicate that there has not been a release from the Title 27 ponds. However, as described in the enclosed Work Plan and in response to the RWQCB's letter, Musco proposes to install three additional groundwater monitoring wells in the vicinity of the Title 27 ponds and modify the existing soil moisture (lysimeter) monitoring system and measurement protocols. Thank you for your attention to the Work Plan. Please contact Ben Hall at (209) 836-4600 or me at(415) 243-2534 should you have any questions or comments regarding the enclosed Work Plan. Very truly yours, KENNEDY/JENKS CONSULTANTS Meredith G. Durant, P.E. Project Manager Enclosure cc: Ben Hall, Musco Family Olive Company Dennis Leikam, Musca Family Olive Company Gary Carlton, Kennedy/Jenks 0S muxaJrve�OYrep�M1stille_1]dnpkrM.Oo: