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California Regional `Vater Quality Control Board QW; Central Valley Region Robert Schneider,Chair a Alan C.Lloyd,Ph.D. Arnold Secretaryfor Sacramento Main Office Schwarzenegger E Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor Protection Phone(916)464-3291 •FAX(916)464-464RECEIVED http://www.waterboards.ca.gov/ccntralvalley l 6 May 2005 MAY 0 J EWRONMENT HEALTH PERMITISEROCES Benjamin Hall Nick Musco Musco Olive Products, Inc. Studley Company f 17950 Via Nicolo 17950 Via Nicolo Tracy, California 95376 Tracy, CA 95376 REQUEST FOR AN E VAL UATION MONITORING PROGRAM CLASS II SURFACE IMPOUNDMENTS, MUSCO OLIVE FAMILY COMPANYAND THE STUDLEY COMPANY, SAN JOAQUIN COUNTY, FACILITYNO. SB392059001 The Musco Olive Family Company and the Studley.Company is the named"Discharger" for the Class H Surface hnpoundments regulated under Waste Discharge Requirements (WDRs) Order No. R5-2005- 0024 and-Title 27 CCR: As part of our Ireview o.rfli&Annual 20041 monitoring and reporting program,Board staff detected increasing concentrations of constituents of concern in monitoring well W-2; specifically total dissolved solids, chloride, sodium (see attached time series graph Figure 1) and nitrate and sulfate (see attached time series graph Figure 2). The attached statistical graphs also show that there is a measurably significantz change in water quality at W-2 based on the Mann Kendall statistical trend analysis. The F Discharger's annual evaluation of the data should have.included this interpretation and notification pursuant to WDRs.and Title 27 CCR §20420 under the Detection Monitoring Program. + Title 27 CCR-section 20420-(i)(3) states, "RWQCB Finding— The provisions of this section shall not preclude the RWQCB from making an independent finding that there is "measurably significant" (see , 20164) evidence of a release from the Unit. If the RWQCB makes such a finding,, the discharger shall comply with the provisions of this section that are required in response to "measurably significant'(see , 20164) evidence of a release from the Unit. " Because of these findings,the Discharger is required to address the release in compliance with Title 27 CCR §20425 Evaluation Monitoring Program (EMP). t Combined reports titled Fourth Quarter 2004 and 2004 Annual Monitoring Summary Report,dated 26 January.2005 as prepared by Dennis Leikam and Benjamin J.Hall and 27 January 2005 as prepared by Joseph D.Zilles and Doug Heard, of Kleinfelder,Inc. s .,Measurably significant'means a change in the Monitoring Point data that,relative to the reference background value(or other approved reference value or distribution),is sufficient to indicate that a release has occurred,pursuant to the applicable data analysis method(including its corresponding trigger) [Title 27 CCR§201641 L California Environmental Protection Agency ��Recycled Paper